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CORRESP
 1
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 CORRESP

 Enova International, Inc. 175 West
Jackson Blvd. Chicago, IL 60604
 Via EDGAR
 December 29, 2025 Securities and Exchange Commission
 Division of Corporation Finance 100 F Street, N.E.
 Washington, D.C. 20549-4628 Attn: Eric Valle

 Re:
 Enova International, Inc.

  
 Amendment No. 1 to Registration on Form S-4

  
 Filed December 29, 2025

  
 File No. 333-292287
 Ladies and Gentlemen: Pursuant to Rule 461
promulgated under the Securities Act of 1933, as amended, Enova International, Inc. hereby respectfully requests that the effective date of the above referenced Registration Statement on Form S-4 be
accelerated to 4:00 p.m., Eastern Time, on December 31, 2025, or as soon as practicable thereafter. Please contact Charlotte May of
Covington & Burling LLP at (202) 662-5732 with any questions you may have regarding this request. In addition, please notify Ms. May by telephone when this request for acceleration has been
granted.

 Respectfully,

 Enova International, Inc.

 By:

 /s/ David Fisher

 Name:

 David Fisher

 Title:

 Chief Executive Officer
 cc: Michael Butler, Grasshopper Bancorp, Inc.
 Charlotte May, Covington & Burling LLP Allison
Schiffman, Covington & Burling LLP Richard A. Schaberg, Hogan Lovells US LLP
 Les B. Reese, III, Hogan Lovells US LLP James Barresi, Squire
Patton Boggs (US) LLP Alison LaBruyere, Squire Patton Boggs (US) LLP

United States securities and exchange commission logo
July 25, 2023
Steven Cunningham
Chief Financial Officer
Enova International, Inc.
175 West Jackson Blvd.
Chicago, IL 60604
Re:Enova International, Inc.
Form 10-K for Fiscal Year Ended December 31, 2022
File No. 001-35503
Dear Steven Cunningham:
            We have completed our review of your filing.  We remind you that the company and its
management are responsible for the accuracy and adequacy of their disclosures, notwithstanding
any review, comments, action or absence of action by the staff.
Sincerely,
Division of Corporation Finance
Office of Finance

CORRESP
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  CORRESP

  July 7, 2023

  William Schroder

  Michael Volley

  U.S. Securities and Exchange Commission

  Division of Corporation Finance

  Office of Finance

  100 F Street, N.E.

  Washington, D.C. 20549

   Re: 	Enova International, Inc.

  Form 10-K for Fiscal Year Ended December 31, 2022

  Filed February 24, 2023

  File No. 001-35503

  Dear Mr. Schroder and Mr. Volley:

  This correspondence is being furnished by Enova International, Inc. (“Enova” or the “Company”) in response to comments contained in the letter dated June 13, 2023 (the “Letter”) from the Staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”) with respect to the Company’s Form 10-K for the fiscal year ended December 31, 2022 (the “2022 Form 10-K”).

  The responses set forth below have been organized in the same manner in which the Commission’s comments were organized and all page references in the Company’s response are to those referenced in any headings or Staff comments. Set forth in italicized print below are the Staff’s comments followed by the Company’s responses.

  Form 10-K filed February 24, 2023

  Bank Programs, page 2

  1. Please refer to comment 1. Please confirm that you will revise future filings to quantify the amounts of purchases and revenue, if materially different, through your bank partner program for each period presented and discuss any trends.

  Enova response: In response to the Staff’s comment, we will supplement our disclosures in our future 10-K filings to disclose the percentages of purchases from our bank partner programs for each period presented and will note any material known trends to the extent relevant. If they materially differ from purchases, we will also disclose the percentages of revenue from our bank partner programs for each period presented and discuss any material known trends to the extent relevant.

  Products and Services, page 2

  2. Please tell us and revise to disclose how you legally recognize loan interest income and how your loans are amortized. For example, disclose if you legally recognize interest income on an accelerated basis. If so, describe how the timing of loan renewals or refinances during the contractual term impact the amount of revenue recognized.

  United States Securities and Exchange Commission

  Division of Corporation Finance

  July 7, 2023

  Page 2

  Enova response: In response to the Staff’s comment, the Company will include additional information on how we recognize interest income and amortize outstanding loan balances.  For example, the following represents the original text included in Part I, Item 1. Business, Products and Services, in our 2022 Form 10-K with marked changes (strikethroughs and underlines) to address the Staff’s comment:

  Our online financing products and services provide customers with a deposit of funds to their bank account in exchange for a commitment to repay the amount deposited plus fees, interest and/or revenue on the receivables purchased. We originate, arrange, guarantee or purchase installment loans, line of credit accounts and RPAs to consumers and small businesses. We have one reportable segment that includes all of our online financial services. Our loans and finance receivables generally have regular payments that amortize principal. Interest income is generally recognized on an effective, non-accelerated yield basis over the contractual term of the installment loan or estimated outstanding period of the draw on line of credit accounts.

  Products and Services, page 2

  3. Please refer to comment 3. Noting the significant range of contractual terms on installment loans, please tell us and revise to disclose the estimated average contractual term.

  Enova response: In response to the Staff’s comment, the Company will disclose the estimated average contractual term on installment loans. For example, the following represents the original text included in Part I, Item 1. Business, Overview, Products and Services in our 2022 Form 10-K with regards to installment loans with cumulative marked changes (strikethroughs and underlines) addressing this and the Staff’s earlier comments.

  Installment loans. Certain subsidiaries (i) directly offer installment loans, (ii) as part of our Bank Programs, purchase or purchase a participating interest in, installment loans or (iii) as part of our CSO program, arrange and guarantee installment loans, as discussed below. Certain subsidiaries offer, or arrange through our Bank Programs and CSO program, unsecured consumer installment loan products in 37 states in the United States and small business installment loans in 47 states and in Washington D.C. Internationally, we also offer or arrange unsecured consumer installment loan products in Brazil. Effective in the third quarter of 2022, Enova no longer offers any single-pay products. Terms for our consumer installment loan products range between threetwo and 60 months with an average contractual term of 43 months. Our loans have regular payments that amortize principal. Loan sizes for these products range between $300 and $10,500. The majority of these loans accrue interest daily at a fixed rate for the life of the loan and have no fees. The average annualized yield for these loans was 72% for the year ended December 31, 2022.  Loans may be repaid early at any time with no additional prepayment charges.

  Certain subsidiaries offer, or arrange through our Bank Programs, small business installment loans in 47 states and in Washington D.C. Terms for these products range between three and 24 months with an average contractual term of 16 months. Our loans have regular payments that amortize principal. Loan sizes for these products range between $5,000 and $250,000. There is generally a fee paid upon origination, and total interest is typically calculated at a fixed rate for the

  United States Securities and Exchange Commission

  Division of Corporation Finance

  July 7, 2023

  Page 3

  life of the loan. A portion of the interest is forgivable if prepaid early, although we also offer a full prepayment forgiveness option at a higher interest rate. The average annualized yield for these products was 46% for the year ended December 31, 2022.

  Marketing, page 8

  4. Please refer to comment 4. To the extent that a reliance on or changes in a particular marketing channel have a material impact on the quality of, and potential variability of your earnings and cash flow, please disclose information necessary for investors to ascertain the likelihood that past performance is indicative of future performance

  Enova response: In response to the Staff’s comment, to the extent that a reliance on or changes in a particular marketing channel have a material impact on the quality of, and potential variability of our earnings and cash flow, the Company will endeavor to disclose in future filings information we believe would be necessary for investors to ascertain the likelihood that past performance is indicative of future performance.

  Consumer Loans and Finance Receivables, page 51

  5. Please refer to comment 8. Noting the impact of the line of credit product on your financial metrics and trends, please tell us and revise future filings to separately present the net revenue margin percentage for each material product in your consumer and small business portfolios tables on pages 51-54.

  Enova response: The following is an excerpt from Item 303(a) of Regulation S-K that discusses part of the objective of the MD&A section:

  The discussion and analysis must be of the financial statements and other statistical data that the registrant believes will enhance a reader's understanding of the registrant's financial condition, cash flows and other changes in financial condition and results of operations. A discussion and analysis that meets the requirements of this paragraph (a) is expected to better allow investors to view the registrant from management's perspective

  As noted in our prior response, Enova manages its products at the portfolio level and does so on a dynamic basis, adapting to evolving market conditions to deliver strong returns at the consolidated and portfolio level. We separately disclose the net revenue margin at the portfolio level for this reason, as well as the fact that we expect the typical ranges for the net revenue margin to differ slightly at the portfolio level (i.e., consumer versus small business). We do not believe that disclosure of net revenue margin for each product within our portfolios is material to the reader’s understanding of our financial results. We follow a risk-based approach to pricing our products. Although the credit risk may differ between certain products within the consumer or small business portfolios, pricing relative to expected credit risk produces portfolio net revenue margins within fairly consistent ranges. We believe that a separate presentation of net revenue margin by product, below the portfolio level, would not be useful for an investor’s understanding of our results as we regularly adjust product mix as market risk and opportunities change.

  United States Securities and Exchange Commission

  Division of Corporation Finance

  July 7, 2023

  Page 4

  In addition, our competitors generally do not disclose net revenue margin by product, which would make Enova more of an outlier.

  To the extent that we believe it is material to a reader’s understanding of our financial condition and results, we will discuss any material known trends in net revenue margin generally at the portfolio level in the MD&A section. If circumstances change and we determine that further disaggregation of net revenue margin to the underlying product level is material to the understanding of Enova’s results, we will also discuss that along with any material known trends in the MD&A section. We believe that the proposed disclosure is optimal and is consistent with Regulation S-K and the objective of the MD&A section as it better allows investors to view Enova’s results from management’s perspective.

  Consumer Loans and Finance Receivables, page 51

  6. Please refer to comment 10. Please tell us and revise future filings to quantify, for each period presented, the dollar amount and percentage of originations by customers borrowing for the first time and returning customers. It appears this information is important for investors to better understand your business and your underlying financial metrics and trends. Please discuss how you define each group as needed.

  Enova response: We do not believe that disclosure of dollar amounts and percentages of originations by new and returning customers is appropriate as it could be misinterpreted by users of our financial statements. There are multiple variables, including originations, that may impact our financial results, but we manage these variables holistically at the portfolio level to deliver strong returns with a focus on both net revenue and EBITDA margins at the portfolio level.  We believe that users of our financial statements may draw false conclusions about our financial results and future prospects if we were to present dollar amounts and percentages of originations by new and returning customers, as this is only one variable in our approach to decision-making. In the past, we have included discussion of new customer mix in the narrative analysis of the MD&A when we deemed it to be meaningful in understanding the credit metrics that underly our financial results. We believe this to be the optimal level of disclosure that allows the reader to view our company from management's perspective and enhance their understanding of our results and financial condition.

  In addition to the above, we also believe that disclosure of dollar amounts and percentages of originations by new and returning customers could be anti-competitive as our competitors may see that we are writing more new business in a portfolio and then alter their origination strategy based on it. This could have a material adverse effect on our business, prospects, results of operations, financial condition and cash flows. In addition, from a comparability standpoint, we do not believe there to be an issue as very few of our competitors disclose dollar amounts and percentages of originations by new and returning customers.

  To the extent we determine that it would meaningfully help a reader understand our financial results, including known material trends, we will continue to include discussion of new customer mix in the narrative analysis of the MD&A.

  United States Securities and Exchange Commission

  Division of Corporation Finance

  July 7, 2023

  Page 5

  Note 3. Loans and Finance Receivables, page 80

  7. Please refer to comment 13. Please provide us your proposed disclosure using amounts as of December 31, 2022.

  Enova response:  In response to the Staff’s comment, we have included the table referenced in the Staff’s original comment, as updated with the suggested addition for accrued interest and fees in blue text that we will add to future filings.

  ******************************************************************************************

  Please do not hesitate to contact me at (312) 517-7425 or scunningham@enova.com with any questions you may have with respect to the foregoing.

  Very truly yours,

    \s\ Steven E. Cunningham

    Steven E. Cunningham

Enova International, Inc

Chief Financial Officer

United States securities and exchange commission logo
June 13, 2023
Steven Cunningham
Chief Financial Officer
Enova International, Inc.
175 West Jackson Blvd.
Chicago, IL 60604
Re:Enova International, Inc.
Form 10-K for Fiscal Year Ended December 31, 2022
Response Dated May 26, 2023
File No. 001-35503
Dear Steven Cunningham:
            We have reviewed your May 26, 2023 response to our comment letter and have the
following comments.  In some of our comments, we may ask you to provide us with information
so we may better understand your disclosure.
            Please respond to these comments within ten business days by providing the requested
information or advise us as soon as possible when you will respond.  If you do not believe our
comments apply to your facts and circumstances, please tell us why in your response.
            After reviewing your response to these comments, we may have additional
comments.  Unless we note otherwise, our references to prior comments are to comments in our
April 28, 2023 letter.
Form 10-K filed February 24, 2023
Bank Programs, page 2
1.Please refer to comment 1.  Please confirm that you will revise future filings to quantify
the amounts of purchases and revenue, if materially different, through your bank partner
program for each period presented and discuss any trends.
Products and Services, page 2
2.Please tell us and revise to disclose how you legally recognize loan interest income and
how your loans are amortized.  For example, disclose if you legally recognize interest
income on an accelerated basis.  If so, describe how the timing of loan renewals or
refinances during the contractual term impact the amount of revenue recognized.

 FirstName LastNameSteven Cunningham
 Comapany NameEnova International, Inc.
 June 13, 2023 Page 2
 FirstName LastName
Steven Cunningham
Enova International, Inc.
June 13, 2023
Page 2
3.Please refer to comment 3.  Noting the significant range of contractual terms on
installment loans, please tell us and revise to disclose the estimated average contractual
term.
Marketing, page 8
4.Please refer to comment 4.  To the extent that a reliance on or changes in a particular
marketing channel have a material impact on the quality of, and potential variability of
your earnings and cash flow, please disclose information necessary for investors to
ascertain the likelihood that past performance is indicative of future performance.
Consumer Loans and Finance Receivables, page 51
5.Please refer to comment 8.  Noting the impact of the line of credit product on your
financial metrics and trends, please tell us and revise future filings to separately present
the net revenue margin percentage for each material product in your consumer and small
business portfolios tables on pages 51-54.
6.Please refer to comment 10.  Please tell us and revise future filings to quantify, for each
period presented, the dollar amount and percentage of originations by customers
borrowing for the first time and returning customers.  It appears this information is
important for investors to better understand your business and your underlying financial
metrics and trends.  Please discuss how you define each group as needed.
Note 3. Loans and Finance Receivables, page 80
7.Please refer to comment 13.  Please provide us your proposed disclosure using amounts as
of December 31, 2022.
            You may contact William Schroeder at 202-551-3294 or Michael Volley at 202-551-
3437 with any questions.
Sincerely,
Division of Corporation Finance
Office of Finance

CORRESP
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  CORRESP

  May 26, 2023

  William Schroder

  Michael Volley

  U.S. Securities and Exchange Commission

  Division of Corporation Finance

  Office of Finance

  100 F Street, N.E.

  Washington, D.C. 20549

    Re:

    Enova International, Inc.

    Form 10-K for Fiscal Year Ended December 31, 2022

    Filed February 24, 2023

    File No. 001-35503

  Dear Mr. Schroder and Mr. Volley:

  This correspondence is being furnished by Enova International, Inc. (“Enova” or the “Company”) in response to comments contained in the letter dated April 28, 2023 (the “Letter”) from the Staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”) with respect to the Company’s Form 10-K for the fiscal year ended December 31, 2022 (the “2022 Form 10-K”).

  The responses set forth below have been organized in the same manner in which the Commission’s comments were organized and all page references in the Company’s response are to those referenced in any headings or Staff comments. Set forth in italicized print below are the Staff’s comments followed by the Company’s responses.

  Form 10-K filed February 24, 2023

  Bank Programs, page 2

  1. Please tell us and revise future filings, here or in MD&A, to discuss the number of and any significant reliance on a particular bank partner and quantify the amount of revenue earned and loans purchased through your bank partner program for each period presented and discuss any trends. Please refer to Item 303(a) of Regulation S-K and SEC Release No. 33-8350 for guidance.

  Enova response: We currently have programs with three separate banks in the United States. In aggregate, purchases under these programs represented 22% of our consolidated originations and purchases for the year ended December 31, 2022, with no individual partner representing more than 12%. In aggregate, revenue earned on loans under these programs represented 23% of our consolidated revenue for the year ended December 31, 2022, with no individual partner representing more than 17%. We do not believe that we have significant reliance on any of our bank partners. Additionally, if there were to be an issue with any one of our current banking partners that disrupted purchases, there would be multiple alternatives to replace any potential reduction in purchases, such as seeking a different banking partner, as there are numerous other banks that have similar relationships with other non-bank lenders. In addition, each of the written agreements with our existing partners requires, in most cases outside of

  United States Securities and Exchange Commission

  Division of Corporation Finance

  May 26, 2023

  Page 2

  bankruptcy or regulatory demand, significant advance notice of intention to terminate and wind down the respective program, which would allow ample time for us to identify and secure alternatives. Another option would be to refocus our capital and marketing efforts on other products and services that do not involve the banking partner. We believe our existing loan portfolio represents less than 1% of what we have identified as the total addressable market in the U.S., and so the bank partnerships are only one way that we can offer diversified products.

  In response to the Staff’s comment, we will supplement our disclosures in our future 10-K filings to disclose the percentage of purchases from our bank partner programs and will note any material known trends to the extent relevant. For example, the following indented section represents the original text included in Part I, Item 1. Business, Overview, Bank Programs in our 2022 Form 10-K with marked changes (underlines) to address the Staff’s comment.

  Bank programs.  Certain subsidiaries operate programs with certain banks to provide marketing services and loan servicing for near-prime unsecured consumer installment loans and, beginning in January 2021, line of credit accounts. Under the programs, those subsidiaries receive marketing and servicing fees. The bank has the ability to sell, and the participating subsidiaries have the option, but not the requirement, to purchase the loans or a participating interest in receivables the bank originates. We do not guarantee the performance of the loans and line of credit accounts originated by the bank. As part of the OnDeck business both prior and subsequent to Enova’s acquisition, OnDeck operates a program with a separate bank to provide marketing services and loan servicing for small business installment loans and line of credit accounts. Under the OnDeck program, we receive marketing fees while the bank receives origination fees and certain program fees. The bank has the ability to sell and we have the option, but not the requirement, to purchase the installment loans the bank originates and, in the case of line of credit accounts, extensions under those line of credit accounts. We do not guarantee the performance of the loans or line of credit accounts originated by the bank.

  As of December 31, 2022, we operate programs with three separate bank partners. Purchases under these programs represented 22% of our consolidated originations and purchases for the year ended December 31, 2022. Management does not deem there to be significant reliance on any of our banking partners.

  The Company respectfully advises the Staff that it will revise its disclosures to include the above information in future 10-K filings.

  Our Markets, page 2

  2. Please tell us and revise future filings, here or in MD&A, to disclose any concentration of originations by state.

  Enova response:  We have reviewed the Staff’s disclosure guidance as well as relevant accounting guidance, which includes, but is not limited to, ASC 275-10-50-16, the Financial Reporting Manual of the Division of Corporation Finance, and 825-10-50-22.  We do not deem state concentration risk or

  United States Securities and Exchange Commission

  Division of Corporation Finance

  May 26, 2023

  Page 3

  disclosure of originations by state to be material to an understanding of our business or financial results. From a credit perspective, the borrower’s state is not a substantial variable in the underwriting process. From a regulatory perspective, as we note in Item 1A, Risk Factors, in our 2022 Form 10-K, state governments may seek to impose new laws, regulatory restrictions or licensing requirements that affect the products or services we offer. We are a diversified company with multiple products and jurisdictions in which we operate. As we have demonstrated in the past, if a particular state in which we currently provide products and services were to impose new laws, regulatory restrictions or licensing requirements that would have an adverse impact on the products or services that we offer in that state, we would shift our efforts, resources, and marketing spend to other jurisdictions to serve our customers, which based on our historical experience would ultimately be expected to have an immaterial net impact to our financial results. For the year ended December 31, 2022, the largest concentration of originations of a product in a single state was 7%.  As we do not deem state origination concentration or state concentration risk to be material to the users of our financial statements, we believe omission of state origination disclosure to be consistent with U.S. GAAP as well as the Commission’s principles-based disclosure approach.

  Products and Services, page 2

  3. Please tell us and revise future filings to provide additional information for each significant loan product to allow an investor to understand the nature of your loan products. At a minimum, discuss the estimated average contractual term, the typical payment structure (e.g. - regular payments that amortize the loan to zero at maturity, interest-only payments, a single payment at maturity, etc.), the typical of fees or interest charged (e.g. – fixed interest rates, variable interest rates, one-time fee based on the principal amount, etc.), and the estimated annual percentage rate, average yield earned or average interest rate charged per loan. Please clarify if any significant loan product includes a single-pay structure and provide the key terms of this loan product. Please refer to Item 303(a) of Regulation S-K and SEC Release No. 33-8350 for guidance.

  Enova response:  In response to the Staff’s comment, the Company will include additional information for each significant loan product to allow investors to better understand the nature of such loan products. For example, the following represents the original text included in Part I, Item 1. Business, Overview, Products and Services in our 2022 Form 10-K with marked changes (strikethroughs and underlines) to address the Staff’s comment. Note that the description of receivables purchase agreements (“RPA”) section will be removed as we have redirected applicants to our other small business offerings and ceased originations of RPAs.

  Installment loans. Certain subsidiaries (i) directly offer installment loans, (ii) as part of our Bank Programs, purchase or purchase a participating interest in, installment loans or (iii) as part of our CSO program, arrange and guarantee installment loans, as discussed below. Certain subsidiaries offer, or arrange through our Bank Programs and CSO program, unsecured consumer installment loan products in 37 states in the United States and small business installment loans in 47 states and in Washington D.C. Internationally, we also offer or arrange unsecured consumer installment loan products in Brazil. Effective in the third quarter of 2022, Enova no longer offers any single-pay products. Terms for our consumer installment loan products range between threetwo and 60 months with regular payments that amortize principal. Loan sizes for these products range

  United States Securities and Exchange Commission

  Division of Corporation Finance

  May 26, 2023

  Page 4

  between $300 and $10,500. The majority of these loans accrue interest daily at a fixed rate for the life of the loan and have no fees. The average annualized yield for these loans was 72% for the year ended December 31, 2022.  Loans may be repaid early at any time with no additional prepayment charges.

  Certain subsidiaries offer, or arrange through our Bank Programs, small business installment loans in 47 states and in Washington D.C. Terms for these products range between three and 24 months with regular payments that amortize principal. Loan sizes for these products range between $5,000 and $250,000. There is generally a fee paid upon origination, and total interest is typically calculated at a fixed rate for the life of the loan. A portion of the interest is forgivable if prepaid early, although we also offer a full prepayment forgiveness option at a higher interest rate. The average annualized yield for these products was 46% for the year ended December 31, 2022.

  Line of credit accounts. Certain subsidiaries directly offer, or purchase a participation interest in receivables through our Bank Programs, new consumer line of credit accounts in 31 states (and continue to service existing line of credit accounts in two additional states) in the United States. and business line of credit accounts in 47 states and in Washington D.C. in the United States, which Line of credit accounts allow customers to draw on their unsecured line of credit in increments of their choosing up to their credit limit, which ranges between $100 and $7,000. Customers may pay off their account balance in full at any time or make required minimum payments in accordance with the terms of the line of credit account. The repayment period varies depending upon certain factors, which may include outstanding principal and differences in minimum payment calculations by product. As long as the customer’s account is in good standing and has credit available, customers may continue to borrow on their line of credit. Customers are charged a fee when funds are drawn and subsequently incur fee- or interest-based charges at a fixed rate, depending upon the product and the state in which the customer resides. The average annualized yield for these products was 212% for the year ended December 31, 2022.

  Certain subsidiaries offer, or arrange through our Bank Programs, new small business line of credit accounts in 47 states and in Washington D.C. in the United States. Terms for these products range between 12 and 24 months with regular payments that amortize principal. Loan sizes for these products range between $5,000 and $100,000.  Interest is calculated at a fixed rate based on the outstanding balance. There is generally no fee paid upon origination with the exception of one of our small business line of credit products, which has an origination fee when allowed by state law.  Certain small business line of credit accounts also charge a monthly maintenance fee. The average annualized yield for these products was 48% for the year ended December 31, 2022.

  The Company respectfully advises the Staff that it will enhance its disclosures along the lines of the above in future 10-K and 10-Q filings.

  Marketing, page 8

  United States Securities and Exchange Commission

  Division of Corporation Finance

  May 26, 2023

  Page 5

  4. We note your disclosure that you have increased the percentage of loans sourced through direct marketing to 41% in 2022 and your disclosure on page 22 that the success of your business depends substantially on the willingness and ability of lead providers or marketing affiliates to provide you with customer leads at acceptable prices. Please tell us and revise future filings, here or in MD&A, to:

  • disclose the percentage of loans sourced through each of your marketing channels for each period presented and discuss any trends, and

  • discuss the number of and any significant reliance on a particular marketing partner. Please refer to Item 303(a) of Regulation S-K and SEC Release No. 33-8350 for guidance.

  Enova response:  Enova views its utilization of various marketing channels as a competitive advantage in a highly competitive environment. We believe that more granular disclosure on the channels we are using, specifically the percentage of loans sourced through each channel for each fiscal period, could be analyzed and used by our competitors to influence the manner in which they market. This could cause competitive harm to us, which would likely have a negative impact on our financial results. Further, we have reviewed the financial fillings of our competitors, noting that most do not disclose this level of detail. Moreover, we do not believe that disclosure of the percentage of loans sourced through each of our marketing channels would be material information for investors or measurably enhance an understanding of our business and financial results.

  In regards to the second bullet in the Staff’s comment, we interact with hundreds of different vendors as it relates to our marketing spend.  For the year ended December 31, 2022, we made payments to over 600 vendors. Due to the large number of vendors (and other potential vendors that we do not currently partner with, but could do so in the future) as well as the versatility of our marketing approach and various channels we can use, we do not have a significant reliance on any particular marketing partner and do not believe discussion of the number of and other information about specific marketing vendors would be material information for investors or measurably enhance an understanding of our business and financial results.

  CFPB, page 13

  5. We note your disclosure that you remain subject to restrictions and obligations, including a prohibition from engaging in certain conduct, related to a January 25, 2019 Consent Order with the CFPB. Please tell us and revise future filings to disclose each significant

United States securities and exchange commission logo
April 28, 2023
Steven Cunningham
Chief Financial Officer
Enova International, Inc.
175 West Jackson Blvd.
Chicago, IL 60604
Re:Enova International, Inc.
Form 10-K for Fiscal Year Ended December 31, 2022
Filed February 24, 2023
File No. 001-35503
Dear Steven Cunningham:
            We have limited our review of your filing to the financial statements and related
disclosures and have the following comments.  In some of our comments, we may ask you to
provide us with information so we may better understand your disclosure.
            Please respond to these comments within ten business days by providing the requested
information or advise us as soon as possible when you will respond.  If you do not believe our
comments apply to your facts and circumstances, please tell us why in your response.
            After reviewing your response to these comments, we may have additional comments.
Form 10-K filed February 24, 2023
Bank Programs, page 2
1.Please tell us and revise future filings, here or in MD&A, to discuss the number of and
any significant reliance on a particular bank partner and quantify the amount of revenue
earned and loans purchased through your bank partner program for each period presented
and discuss any trends. Please refer to Item 303(a) of Regulation S-K and SEC Release
No. 33-8350 for guidance.
Our Markets, page 2
2.Please tell us and revise future filings, here or in MD&A, to disclose any concentration of
originations by state.

 FirstName LastNameSteven Cunningham
 Comapany NameEnova International, Inc.
 April 28, 2023 Page 2
 FirstName LastNameSteven Cunningham
Enova International, Inc.
April 28, 2023
Page 2
Products and Services, page 2
3.Please tell us and revise future filings to provide additional information for each
significant loan product to allow an investor to understand the nature of your loan
products.  At a minimum, discuss the estimated average contractual term, the typical
payment structure (e.g. - regular payments that amortize the loan to zero at maturity,
interest-only payments, a single payment at maturity, etc.), the typical of fees or interest
charged (e.g. – fixed interest rates, variable interest rates, one-time fee based on the
principal amount, etc.), and the estimated annual percentage rate, average yield earned or
average interest rate charged per loan.  Please clarify if any significant loan product
includes a single-pay structure and provide the key terms of this loan product.  Please
refer to Item 303(a) of Regulation S-K and SEC Release No. 33-8350 for guidance.
Marketing, page 8
4.We note your disclosure that you have increased the percentage of loans sourced through
direct marketing to 41% in 2022 and your disclosure on page 22 that the success of your
business depends substantially on the willingness and ability of lead providers or
marketing affiliates to provide you with customer leads at acceptable prices.  Please tell us
and revise future filings, here or in MD&A, to:

•disclose the percentage of loans sourced through each of your marketing channels for
each period presented and discuss any trends, and
•discuss the number of and any significant reliance on a particular marketing partner.

Please refer to Item 303(a) of Regulation S-K and SEC Release No. 33-8350 for guidance.
CFPB, page 13
5.We note your disclosure that you remain subject to restrictions and obligations, including
a prohibition from engaging in certain conduct, related to a January 25, 2019 Consent
Order with the CFPB.  Please tell us and revise future filings to disclose each significant
provision under the terms of the Consent Order, the actions you have taken or you plan to
take to comply with each provision and the current status of your compliance.
Additionally, please discuss how your actions will impact future financial results and
trends including credit quality trends and discuss what the steps needed for the CFPB to
terminate the Consent Order.
Results of Operations, page 43
6.We note your disclosure on page 73 that revenue includes: interest income, finance
charges, fees for services provided through the Company’s CSO programs, revenue on
RPAs, service charges, draw fees, minimum billing fees, purchase fees, origination fees,
late fees and non-sufficient funds fees.  Noting the different nature the sources of revenue,
please tell us and revise future filings to separately disclose each significant revenue

 FirstName LastNameSteven Cunningham
 Comapany NameEnova International, Inc.
 April 28, 2023 Page 3
 FirstName LastNameSteven Cunningham
Enova International, Inc.
April 28, 2023
Page 3
amount for each period presented and discuss any trends.  Please refer to Item 303(a) of
Regulation S-K and SEC Release No. 33-8350 for guidance.
Loan and Finance Receivable Balances, page 48
7.Please tell us and revise future filings to explain the relationship between the average loan
and finance receivable origination amount in the table at the bottom of page 49 and the
average amount outstanding per loan and finance receivable amount in the table at the top
of page 49.  Specifically describe why the origination amount is significantly smaller than
the amount outstanding.
Consumer Loans and Finance Receivables, page 51
8.We note your discussion of the different revenue and credit characteristics of line of credit
products here and in the small business loans section on page 54.  Please tell us and revise
future filings to disclose the information presented in the tables on pages 51 -54 separately
for installment loans, lines of credit, and any other material loan product.  Please refer to
Item 303(a) of Regulation S-K and SEC Release No. 33-8350 for guidance.
9.We note your discussion related to the impact that the amount of originations has on your
profitability and credit trends.  Please tell us and revise future filings to include the
amount of originations in the tables on pages 51-54 by loan product and discuss any
trends.  Please refer to Item 303(a) of Regulation S-K and SEC Release No. 33-8350 for
guidance.
10.We note your discussion during your 2022 fourth quarter earnings conference call that
originations from new customers during the quarter was 42% of total originations and
your disclosure on page 52 that new customers typically have a higher default rate than
returning customers.  Please tell us and revise future filings to quantify, for each period
presented, the dollar amount and percentage of originations by new customer and
returning customers.  To the extent there is a significant difference, please clarify if
returning customers typically represent renewals of existing loans or new loans.
11.We note your discussion on page 6 that if a loan is renewed or refinanced, it is considered
a new loan.  Please tell us and revise your disclosure of significant accounting policies in
your financial statements in future filings to discuss how you determine whether a renewal
is accounted for as a new loan or as a modification.  Please tell us the guidance you
considered in making your determination.
Current and Delinquent Loans and Finance Receivables, page 74
12.To the extent material, please tell us and revise future filings, here or in MD&A, to
disclose the amount of payment deferrals in each period presented and the impact on
financial results and trends.

 FirstName LastNameSteven Cunningham
 Comapany NameEnova International, Inc.
 April 28, 2023 Page 4
 FirstName LastName
Steven Cunningham
Enova International, Inc.
April 28, 2023
Page 4
Note 3. Loans and Finance Receivables, page 80
13.Please tell us and revise future filings to disclose the amount of accrued interest and fees
included in the principal balances in the table on the bottom of page 80.
14.Please tell us and revise future filings to clarify if “Originations and acquisitions” in the
rollforward on page 81 is presented on a cost basis or a fair value basis.
            In closing, we remind you that the company and its management are responsible for the
accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or
absence of action by the staff.
            You may contact William Schroeder at 202-551-3294 or Michael Volley at 202-551-
3437 with any questions.
Sincerely,
Division of Corporation Finance
Office of Finance

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CORRESP

 September 4, 2020

VIA EDGAR

 United States Securities and Exchange Commission

Division of Corporation Finance

 100 F Street, N.E.

Washington, D.C. 20549

 Attention: Ms. Sonia
Bednarowksi

Re:
 Enova International, Inc.

 Request for Acceleration of Effectiveness of Form S-4

 SEC File No. 333- 248400 (“Registration Statement”)

Dear Ms. Bednarowski:

 On behalf of Enova
International, Inc., as registrant, the undersigned hereby requests that the effective date for the Registration Statement, as amended, be accelerated so that it will become effective at 4:00 p.m. (Washington, D.C. time), or as soon as
practicable thereafter, on Tuesday, September 8, 2020.

 Feel free to telephone Christopher G. Barrett of Vedder Price P.C., the
registrant’s legal counsel, at (312) 609-7557 with any questions or comments.

 Very truly yours,

Enova International, Inc.

/s/ Christopher A.
McVety

Christopher A. McVety

Senior Associate General Counsel

United States securities and exchange commission logo
August 27, 2020
David Fisher
Chief Executive Officer
Enova International, Inc.
175 West Jackson Blvd.
Chicago, IL 60604
Re:Enova International, Inc.
Registration Statement on Form S-4
Filed August 25, 2020
File No. 333-248400
Dear Mr. Fisher:
            This is to advise you that we have not reviewed and will not review your registration
statement.
            Please refer to Rules 460 and 461 regarding requests for acceleration.  We remind you
that the company and its management are responsible for the accuracy and adequacy of their
disclosures, notwithstanding any review, comments, action or absence of action by the staff.
            Please contact Sonia Bednarowski at 202-551-3666 or Justin Dobbie, Legal Branch
Chief, at 202-551-3469 with any questions.
Sincerely,
Division of Corporation Finance
Office of Finance

CORRESP
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CORRESP

 September 15, 2015

Mr. Michael Clampitt

VIA EDGAR

 Senior Counsel

 United States
Securities and Exchange Commission

 Division of Corporate Finance

101 F Street, NE

 Washington, DC 20549

Re:
Enova International, Inc.

Registration Statement on Form S-1 (File No. 333-199733)

 Dear Mr. Clampitt:

Reference is made to the Registration Statement on S-1 (File No. 333-199733) (as amended, the “Registration Statement”), filed
by Enova International, Inc. (the “Company”) with the U.S. Securities and Exchange Commission (the “Commission”).

Pursuant to Rule 461 under the Securities Act of 1933, as amended (the “Securities Act”), the Company hereby requests acceleration
of the effectiveness of the Registration Statement to 3:00 p.m., Washington, D.C. time, on Tuesday, September 15, 2015, or as soon thereafter as is practicable.

The Company acknowledges that the adequacy and accuracy of the disclosure in the Registration Statement is the responsibility of the Company.
The Company further acknowledges that:

•

Should the Commission or the staff of the Commission (the “Staff”), acting pursuant to delegated authority, declare the filing effective, it does not foreclose the Commission from taking any action with
respect to the filing;

•

The action of the Commission or the Staff, acting pursuant to delegated authority, in declaring the filing effective, does not relieve the Company from its full responsibility for the adequacy and accuracy of the
disclosure in the filing; and

•

The Company may not assert the Staff comments and the declaration of effectiveness as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.

 Please contact the undersigned at (312) 676-1591 with any questions you may have concerning this request. Upon grant
of our request to accelerate effectiveness, we would appreciate your communicating to the Company’s counsel, L. Steven Leshin, via telephone at (214) 468-3348, or Lindsay Ferguson, via telephone at (214) 468-3343, confirmation of the
exact time at which the Registration Statement was declared effective.

Very truly yours,

ENOVA INTERNATIONAL, INC.

By:

/s/ Lisa M. Young

Lisa M. Young

Vice President—General Counsel & Secretary

cc:
L. Steven Leshin, Esq.

Lindsay H. Ferguson, Esq.

CORRESP
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CORRESP

 HUNTON & WILLIAMS LLP

FOUNTAIN PLACE

1445 ROSS AVENUE

SUITE 3700

DALLAS, TEXAS 75202-2799

TEL    214 • 979 • 3000

FAX   214 • 880 • 0011

 June 5, 2015

 Via EDGAR

 Mr. Raymond Be, Office of Chief Counsel

Mr. Dietrich King, Assistant Director

 United States
Securities and Exchange Commission

 101 F Street, NE

Washington, D.C. 20549

Re:
Enova International, Inc.

 Registration Statement on Form S-1 (the
“Registration Statement”)

 File No. 333-199733

Messrs. Be and King:

 On behalf of Enova
International, Inc. (the “Company”), we are transmitting this letter to address the matters discussed on our call held on Friday, May 22, 2015.

Discussion of Staff Legal Bulletin No. 4

The Securities and Exchange Commission (the “SEC”) has stated that a dividend of securities generally does not constitute a
“sale” within the meaning of Section 2(a)(3) of the Securities Act of 1933, as amended (the “Securities Act”), because such dividend does not constitute a disposition “for value” within the meaning of that section.
See Securities Act Release No. 33-929 (July 29, 1936). The Staff of the SEC issued Staff Legal Bulletin No. 4 dated December 16, 1997 (the “Staff Bulletin”) to address whether Section 5 of the Securities Act
applies to spin-offs. The Staff Bulletin states that a subsidiary does not have to register its shares under the Securities Act if the following five conditions are met:

1.
the parent shareholders do not provide consideration for the spun-off shares;

2.
the spin-off is pro-rata to the parent shareholders;

3.
the parent provides adequate information about the spin-off and the subsidiary to its shareholders and to the trading markets;

4.
the parent has a valid business purpose for the spin-off; and

 United States Securities and Exchange Commission

Messrs. Raymond Be and Dietrich King

 June 5, 2015

Page 2

5.
if the parent spins-off “restricted securities,” it has held those securities for at least two years.

The Company respectfully submits that Cash America International, Inc., a Texas corporation (“Cash America”), and the Company
complied with the Staff Bulletin and met all five conditions set forth above in connection with the tax-free distribution of approximately 80% of the Company’s issued and outstanding common stock to Cash America’s shareholders (the
“Spin-off”).

 We will discuss each condition in turn:

1.
The parent shareholders do not provide consideration for the spun-off shares

 In the
Spin-off, Cash America’s shareholders received shares of the Company’s common stock and were not required to make, and did not make, any payment or provide any consideration for the shares received.

2.
The spin-off is made pro rata to parent’s shareholders

 The Spin-off was made on a
pro rata basis to all of Cash America’s shareholders in proportion to each shareholder’s proportionate share ownership in Cash America. Each Cash America shareholder of record on the record date for the Spin-off received 0.915 shares of
Enova common stock for every one share of Cash America common stock held on the record date. The Cash America shareholders had the same proportionate ownership interest in the Company and Cash America both before and after the distribution.
Furthermore, fractional shares were handled in a manner that satisfied Question 6 of the Staff Bulletin. Fractional share interests were aggregated into whole shares and sold in the open market at prevailing market prices by an independent
distribution agent and the aggregate net cash proceeds of the open market sales were distributed pro rata, to each holder who would have otherwise received a fractional share. The distribution agent, in its sole discretion, without any influence of
Cash America or the Company, determined when, how and through which broker-dealer, and at what price to sell the whole shares, and the distribution agent was not an affiliate of either Cash America or the Company.

3.
The parent must provide adequate information to its shareholders and the trading markets

 United States Securities and Exchange Commission

Messrs. Raymond Be and Dietrich King

 June 5, 2015

Page 3

 Cash America satisfied the requirement of providing adequate information by filing the Form
10 (File No. 001-35503), including the Information Statement contained as Exhibit 99.1 (the “Information Statement”), to register the Company’s shares under the Securities Exchange Act of 1934, as amended (the “Exchange
Act”), and mailing to Cash America’s shareholders the Information Statement. The Information Statement described the Spin-Off and the Company and substantially complied with Regulation 14A or Regulation 14C under the Exchange Act, as
called for by the Staff Bulletin. The Company discussed this specific condition in its response letter, dated September 12, 2014, to the Staff’s comment letter, dated August 26, 2014, on the Company’s Registration Statement on
Form 10.

4.
The parent has a valid business purpose for the spin-off

 Cash America’s Board of
Directors determined that there were valid business purposes for the Spin-off. In this regards, Cash America’s Board of Directors determined that the separation of Cash America’s storefront retail business and the Company’s online
financial services business and the Spin-off would achieve a number of business purposes. The following benefits were set forth on pages 64 to 65 of the Information Statement:

•

Strategic Focus and Operational Flexibility. Position each company to pursue a more focused, industry-specific strategy, with the Company well-positioned to pursue value creation strategies in the online
financial services business and beyond, and Cash America well-positioned to focus on its remaining storefront retail services business, and create additional operational flexibility within each of the Company and Cash America.

•

Management Focus. Allow management of each company to concentrate that company’s resources wholly on its particular market segments, regulatory requirements, customers and core lending businesses, with
greater ability to anticipate and respond rapidly to changing markets and new opportunities.

•

Isolation of regulatory oversight and risks for each company. Allow for better definition of regulatory responsibilities, implementation of more efficient compliance activities and relations with regulators that
are more focused on each company’s distinct operations. In addition, the risk profile for each company will be directly aligned to each company’s operations.

•

 Recruiting and Retaining Employees. Allow each company to recruit and retain employees with expertise directly applicable to its needs and
pursuant to compensation

 United States Securities and Exchange Commission

Messrs. Raymond Be and Dietrich King

 June 5, 2015

Page 4

policies that are appropriate for its specific lines of business. In particular, following the distribution, the value of equity-based incentive compensation arrangements offered by each company
should be more closely aligned with the performance of its businesses, and the employee benefits offered by each company should be better tailored to the nature of each company’s business.

•

Access to Capital and Capital Structure. Eliminate competition for capital between the business lines. Instead, both companies will have direct access to the debt and equity capital markets to fund their
respective growth strategies and to establish a capital structure and dividend policy appropriate for their business needs.

•

Distinct investment identity. Enable investors to evaluate the merits, performance and future prospects of each company’s businesses and to invest in each company separately based on these distinct
characteristics and the investor’s particular different industry focus, investment goals and risk profile.

 The Staff
Bulletin states that “the parent must determine whether there is a valid business purpose for the spin-off.” The Company has been advised that Cash America determined that these constituted valid business purposes for the Spin-off, and the
Company believes that these were valid business purposes for the Spin-off.1

 While
the Staff Bulletin provides that “the facts of a particular situation will determine whether the business purpose is valid,” the Staff Bulletin goes on to say that the Staff has recognized the following examples as valid business purposes
for a spin-off: (i) “allowing management of each business to focus solely on that business,” (ii) “providing employees of each business stock-based incentives linked solely to his or her employer,”
(iii) “enhancing access to financing by allowing the financial community to focus separately on each business,” or (iv) “enabling the companies to do business with each other’s competitors.” Three of these examples
of valid business purposes are in sync with Cash America’s business purposes for the Spin-off set forth in the Information Statement.

Furthermore, the Staff Bulletin also provides three examples of invalid business purposes: (i) “creating a market in the spun-off
securities without providing adequate

1
 As discussed in this letter under “Private Letter Ruling and Request,” the tax-free characterization of the Spin-off required that the
Spin-off be carried out for one or more corporate business purposes.

 United States Securities and Exchange Commission

Messrs. Raymond Be and Dietrich King

 June 5, 2015

Page 5

information to the shareholders or to the trading markets,” (ii) “the creation of a public market in the shares of a company that has minimal operations or assets,” or
(iii) “the creation of a public market in the shares of a company that is a development stage company that has no specific business plan or whose business plan is to engage in a merger or acquisition with an unidentified company.”
None of these three invalid business purposes are applicable to the Company as (x) adequate information was provided to Cash America’s shareholders and the trading markets as discussed above, (y) the Company did not have minimal
operations or assets and (z) the Company’s business was not in any development stage and there were no plans for the Company to engage in a merger or acquisition following the Spin-off.

5.
If the parent spins-off “restricted securities,” the parent must have held those securities for at least two years

The Staff Bulletin states that the two-year holding period condition does not apply where the parent formed the subsidiary being spun-off,
rather than acquiring the business from a third-party. Cash America formed the Company on September 7, 2011, and accordingly, the Company respectfully submits that this final condition has been satisfied. Additionally, Cash America held the
shares for more than two years prior to the Spin-off, which also satisfies this condition.

 Discussion of Spin-offs of Less Than All of a
Subsidiary’s Shares

 The Staff Bulletin states that “[i]n a spin-off, a parent company distributes shares of a subsidiary to
the parent company’s shareholders.” The Staff Bulletin does not provide that the parent company is required to distribute all of the shares of a subsidiary to the parent company’s shareholders. In some cases, a parent may
distribute fewer than all of the shares of the spin-off company.

 In order for a partial spin-off to be tax-free, the parent must
generally distribute “control” of the spin-off company, as determined pursuant to the Internal Revenue Code (the “Code”) (i.e., at least 80% of the voting power of all of the shares and at least 80% of any non-voting
shares of the spin-off company), and the parent must establish to the satisfaction of the Secretary of the Treasury that it has a valid business purpose for retaining any shares of the spin-off
company.2

2
The additional requirement of having to satisfy the Secretary of the Treasury that a valid business purpose exists for retaining shares is likely a reason why 100% spin-offs are more common than partial spin-offs.

 United States Securities and Exchange Commission

Messrs. Raymond Be and Dietrich King

 June 5, 2015

Page 6

 While it is more common for parent companies to spin-off 100% of the shares of the company
being spun-off, other companies have engaged in partial spin-offs. We reviewed spin-off transactions that were filed with SEC on Form 10 over the last six years and we identified the following partial spin-offs filed in reliance on the Staff
Bulletin, in addition to the Company’s Spin-off:3

1.
Gannett Co., Inc.’s proposed spin-off of 98.5% of the outstanding shares of common stock of Gannett SpinCo, Inc. (File No. 001-36874) (Form 10 originally filed on March 12, 2015 and is currently in
process);

2.
Baxter International Inc.’s proposed spin-off of approximately 80.5% of the outstanding shares of common stock of Baxalta Incorporated (File No. 001-36782) (Form 10 originally filed on December 10, 2014
and is currently in process);

3.
Inland American Real Estate Trust, Inc.’s spin-off of 95% of the outstanding shares of common stock in Xenia Hotels & Resorts, Inc. (File No. 001-36594) (Form 10 originally filed on August 11,
2014 and effective in January 2015);

4.
Occidental Petroleum Corporation’s spin-off of at least 80.1% of the outstanding shares of common stock in California Resources Corporation (File No. 001-35743) (Form 10 originally filed June 5, 2014 and
effective on October 14, 2014);

5.
Tribune Company’s spin-off of 98.5% of the outstanding shares of common stock of Tribune Publishing Company (File No. 001-36230) (Form 10 originally filed December 9, 2013 and effective on July 21,
2014);

6.
Valero Energy Corporation’s spin-off of 80% of the outstanding shares of common stock of Corner Store Holdings, Inc. (File No. 001-35743) (Form 10 originally filed November 16, 2012 and effective on
April 9, 2013);

7.
Ralcorp Holdings, Inc.’s spin-off of at least 80% of the outstanding shares of common stock of Post Holdings, Inc. (File No. 001-35305) (Form 10 originally filed on September 26, 2011 and effective on
January 23, 2012);

3
None of the nine partial spin-offs listed involve spin-offs following an initial public offering, which was referred to in our telephone conference as one way in which companies effect spin-offs.

 United States Securities and Exchange Commission

Messrs. Raymond Be and Dietrich King

 June 5, 2015

Page 7

8.
Atlas Energy, L.P.’s spin-off of approximately 19.6% of its limited partner interest in Atlas Resource Partners, L.P. (File No. 001-35317) (Form 10 originally filed on October 17, 2011 and effective on
February 14, 2012); and

9.
Cardinal Health, Inc.’s spin-off of at least 80% of the outstanding shares of common stock in CareFusion Corporation. (File No. 001-34273) (Form 10 originally filed March 31, 2009 and effective on
July 24, 2009).

 We also have identified correspondence wherein the Staff has previously directly addressed and
accepted a registrant’s ability to rely on the Staff Bulletin in connection with a partial spin-off. Specifically, in a Staff comment letter dated November 15, 2011, the Staff requested Atlas Resource Partners, L.P. (“Atlas
Resource”) to provide a written analysis with respect to its eligibility to rely on the Staff Bulletin in connection with a partial spin-off of approximately 20% of Atlas Resource’s limited partnership interests by its parent Atlas Energy,
LP. See Atlas Resource Partners, dated November 15, 2011. In comment no. 8, the Staff wrote:

 “We note that you are not
registering the distribution of the registrant’s units to the unitholders of Atlas Energy, LP. If you intend to rely on Staff Legal Bulletin No. 4, please provide a detailed written analysis with respect to your eligibility to rely on such
interpretation. Please ensure that your response includes, without limitation, an analysis regarding how the distribution will be pro rata to the unitholders of Atlas Energy, LP.”

In a letter t

CORRESP
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CORRESP

 HUNTON & WILLIAMS LLP

 FOUNTAIN PLACE

1445 ROSS AVENUE

 SUITE 3700

DALLAS, TEXAS 75202-2799

TEL    214 • 979 • 3000

FAX   214 • 880 • 0011

 September 10, 2015

Mr. Michael Clampitt

 Senior Counsel

United States Securities and Exchange Commission

 101 F Street,
NE

 Washington, D.C. 20549

Re:
Enova International, Inc.

Registration Statement on Form S-1

Filed September 10, 2015

File No. 333-199733

 Ladies and Gentlemen:

Further to the Staff’s comment letter dated March 23, 2015 and our telephone conferences with the Staff, Enova International, Inc.
(the “Registrant”) acknowledges that Cash America International, Inc. (“Cash America”) is not now a parent of the Registrant and will not be a parent of the Registrant at the effective time of the above-referenced Registration
Statement. The Registrant respectfully submits that Cash America is eligible to offer the shares covered by the Registration Statement in accordance with Rule 415(a)(1)(i) because, at the effective time of the Registration Statement, Cash
America will not be a parent of the Registrant. This letter is being filed on EDGAR concurrently with the filing of Amendment No. 2 to the Registration Statement.

The Registrant acknowledges that (i) the Registrant is responsible for the adequacy and accuracy of the disclosure in the filing;
(ii) Staff comments or changes to disclosure in response to Staff comments do not foreclose the Commission from taking any action with respect to the filing; and (iii) the Registrant may not assert Staff comments as a defense in any
proceeding initiated by the Commission or any person under the federal securities laws of the United States.

 Please do not hesitate to
call the undersigned at the number referenced above if you have any questions or comments regarding the foregoing.

 United States Securities and Exchange Commission

Mr. Michael Clampitt

 September 10, 2015

Page 2

 Sincerely,

 /s/ L. Steven Leshin

 L. Steven Leshin

cc:
Lisa M. Young, Esq.

Kirkland & Ellis LLP

March 23, 2015

Via E -mail
David A. Fisher
President and Chief Executive Officer
Enova International, Inc.
200 West Jackson Blvd.
Chicago, IL 60606

Re: Enova International, Inc.
Amendment No. 1 to Registration Statement on Form S -1
Response dated  February 10, 2015
  File No. 333-199733

Dear Mr. Fisher :

We have reviewed the above referenced response letter  and have the following
comments.   In some of our comments, we may ask you to provide us with information so we
may better understand your disclosure.

Please respond to this letter by amending your regi stration statement and providing the
requested information.   Where you do not believe our comments apply to your facts and
circumstances or do not believe an amendment is appropriate, please tell us why in your
response.

After reviewing any amendment to  your registration statement and the information you
provide in response to these comments, we may have additional comments.

1. We note your response to prior comment 1 and are unable to concur with your analysis.
In particular, we continue to believe tha t as Enova’s sole stockholder and parent, Cash
America possessed the power to direct or cause the direction of the management and
policies of Enova when the separation -related agreements were negotiated and entered
into.  Although such agreements were subj ect to approval by an independent board of
directors, we note that the five outside, independent directors were elected on October 1,
2014 by Cash America in its capacity as Enova’s sole stockholder.   Noting that Cash
America retained all of the ownership interest in Enova’s common stock when the
separation -related agreements were negotiated and entered into, we are unable to concur
with your view that the negotiations over such agreements and the requisite approval of
the same by Enova’s independent board had mitigated Cash America’s actual control of
Enova prior to the spin -off.  We continue to believe that these securities, when registered
pursuant to the registration statement, were offered by or on behalf of the registrant and
that, at this time, you ar e not eligible to conduct an at -the-market offering under Rule

David A. Fisher
Enova International, Inc.
March 23, 2015
Page 2

 415(a)(4) under the Securities Act because you are not eligible to conduct  an offering
under Rule 415(a)(1)(x).   Please revise or advise.

Please contact David Lin at (202) 551 -3552 or me at (202) 551 -3434 with any questions.

Sincerely,

 /s/ David Lin for

Michael Clampitt
Senior Counsel

cc: Lisa M. Young, Esq.
L. Steven Leshin, Esq.

CORRESP
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Correspondence

 HUNTON & WILLIAMS LLP

FOUNTAIN PLACE

 1445 ROSS AVENUE

SUITE 3700

DALLAS, TEXAS 75202-2799

 TEL

 FAX

 214 • 979 • 3000

214 • 880 • 0011

 February 10, 2015

Mr. Michael Clampitt

 Senior Counsel

United States Securities and Exchange Commission

 101 F Street,
NE

 Washington, D.C. 20549

Re:
Enova International, Inc.

 Amendment No. 1 to Registration Statement on Form S-1

 Filed December 5, 2014

File No. 333-199733

 Ladies and
Gentlemen:

 On behalf of Enova International, Inc. (the “Company”), we are transmitting the following responses of the Company
to the comments of the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”), as set forth in the letter of Mr. Michael Clampitt, Senior Counsel, dated January 15, 2015 (the “Comment
Letter”), regarding the above-referenced registration statement on Form S-1 (the “Registration Statement”). For your convenience, we have repeated the comment in italics prior to the response.

Registration Statement on Form S-1

1.
 We note your response to prior comment 2 in our letter dated November 18, 2014. Based on your response, we are unable to concur with your view
that the subject transaction is appropriately characterized as a secondary offering under Rule 415(a)(1)(i). In this regard, we note that prior to November 13, 2014, Cash America was your parent company and owned all of the outstanding shares
of your common stock. Given that Cash America was your parent both at the time the instant registration statement (File No. 333-199733) was filed on October 30, 2014 and when you and Cash America entered into the Stockholder’s and
Registration Rights Agreement on November 12, 2014, it appears that the transaction represents a primary offering on behalf of the Company. Additionally, we note that pursuant to the Transition Services Agreement, dated November 12, 2014,
Cash America will provide to the Company certain services for a transitional period, including, without limitation, the maintenance of existing general ledger accounts and the opening/closing of monthly periods. See Schedule 1 to

 United States Securities and Exchange Commission

Mr. Michael Clampitt

 February 10, 2015

 Page
 2

the Transition Services Agreement. Therefore, certain aspects of the offering continue to cause us to believe that the transaction should be viewed as a primary offering on behalf of the Company
and not a secondary offering as contemplated by Rule 415(a)(1)(i). Please revise or advise.

 Company Response:

 A. Timing of Filing of the Registration Statement and the Entering Into of the Stockholder’s and Registration Rights Agreement

 In our discussions with the Staff, the Staff explained that the Staff did not view the offering of the Company’s shares by Cash
America International, Inc. (“Cash America”) to be a secondary offering of shares by Cash America but viewed it as a disguised primary offering by the Company because at the time of the filing of the Registration Statement and entering
into of the Stockholders’ and Registration Rights Agreement (the “Registration Rights Agreement”) Cash America held all of the stock of the Company and had control over the Company. We advised the Staff that the terms of the
Registration Rights Agreement were not unilaterally established by Cash America. We discussed with the Staff that although at that time Cash America held all of the stock of the Company, procedures established by Cash America and extant
circumstances resulted in a more robust bargaining as to the terms of the registration rights than the Staff had inferred. The Company respectfully submits that the facts and circumstances discussed in this response letter demonstrate that at the
time that the Registration Statement was filed and the Registration Rights Agreement was entered into, the terms of the Registration Rights Agreement and the other four separation-related agreements were negotiated between the parties
notwithstanding Cash America’s share ownership.

 First, to understand how there could exist a negotiating environment between the
Company and Cash America, it is critical to understand the relationship between the Company and Cash America. A culture of separateness existed between the two companies largely because the e-commerce business (conducted through the Company) and the
retail services business (conducted through Cash America) are distinct and dissimilar businesses that were operated largely independently prior to the spin-off. Further underpinning the sense of separateness or independence was that the
Company’s business was conducted and directed through its own management team from a geographically distinct location. The Company’s headquarters are located in Chicago, Illinois, and Cash America’s headquarters are located in Fort
Worth, Texas. This is as a result of the purchase of the Company (then known as

 United States Securities and Exchange Commission

Mr. Michael Clampitt

 February 10, 2015

 Page
 3

CashNetUSA) by Cash America in 2006 from its private owners who had established the Company just three years earlier. Because the businesses were distinct, the Company continued to operate
autonomously with no management from Cash America relocated to Chicago to supervise the business. Some services were shared between the companies at various times during the eight years that the Company was owned by Cash America, but many
traditional shared services such as human resources, information technology, accounting (except for accounts payable), marketing and legal were managed largely by the Company. In addition, the Company maintained its own management team, had its own
chief executive officer, had its own general counsel, and since July, 2014, had its own outside, independent law firm, Kirkland & Ellis LLP, all separate from Cash America.

Second, Cash America and the Company recognized the potential conflict inherent from the fact that the Company was a wholly owned subsidiary
negotiating the separation-related agreements with its parent company and that the Company’s interests as a new public company and the interests of its future stockholders could diverge from the interests of Cash America. To assuage these
concerns that the Company and Cash America had, Cash America and the Company determined that it was in the best interest of Cash America’s shareholders and the future shareholders of the Company that the Company have an independent board of
directors prior to the spin-off to review, consider and approve, among other things, the separation-related agreements and the Registration Statement.1 The members of the board of directors were
personally recruited by the Company’s Chief Executive Officer, with assistance from the recruiting firm Crist Kolder Associates pursuant to a letter agreement signed on March 10, 2014. On October 1, 2014, Cash America, in its capacity
as sole stockholder of the Company, elected seven directors to serve as the Company’s board of directors, five of whom are outside, independent directors, one of whom is the Company’s Chief Executive Officer and the other is Daniel R.
Feehan, Cash America’s chief executive officer. The five outside, independent directors were identified and slated to become independent directors by the Chief Executive Officer of the Company and they have no relationship or prior involvement
or business dealings

1
 While one might infer that management of the Company had little leverage in the negotiations since they were ultimately employees of Cash America,
this would be too narrow of a view of the circumstances. The buy-in and support of Company management for the spin-off was considered by Cash America to be critical to the feasibility of the spin-off. As a result, in negotiating the
separation-related agreements, Cash America solicited and sought to address concerns and changes proposed by Company management and its counsel to avoid jeopardizing the success of the spin-off (which Cash America believed could be jeopardized if
key employees terminated their employment with the Company prior to the spin-off due to their dissatisfaction with the process of preparing separation-related agreements and the terms themselves).

 United States Securities and Exchange Commission

Mr. Michael Clampitt

 February 10, 2015

 Page
 4

with Cash America. Mr. Feehan was asked by the Company’s Chief Executive Officer to join the Company’s Board so that the Company could have the benefit of Mr. Feehan’s industry
experience and not as a representative of Cash America. As discussed in the timeline below, it is this board of directors who reviewed, considered and, at a board meeting held on October 14, 2014, approved the separation-related agreements and
the filing of the Registration Statement and who signed the Registration Statement. Furthermore, the Company respectfully advises the Staff that no person from Cash America attended this meeting of the Company’s board of directors, except for
Mr. Feehan. Mr. Feehan attended in his capacity as a director of the Company and not in his capacity as an officer of Cash America. The meeting was attended by all seven directors, certain individuals from the Company’s management
team, including the Company’s general counsel, and the Company’s outside legal counsel from Kirkland & Ellis LLP. 2

In connection with the spin-off, the Company and Cash America entered into five separation-related agreements to govern the relationship of
the Company and Cash America after the spin-off was completed. These agreements were described in the Company’s December 4, 2014 response letter. The terms of these agreements were not unilaterally established by Cash America. To the
contrary, Cash America furnished drafts of these agreements to the Company’s management for their review, consideration and comment, and the Company and Cash America exchanged comments and proposed changes and engaged in multiple discussions to
negotiate the terms of these agreements. During this process, the Company was represented by its own outside legal counsel and its separate in-house general counsel in the negotiations of these agreements.

2
This process established by the Company and Cash America is commonly employed to address interested party transactions to remove any conflict taint. For example, see Section 144 of the Delaware General Corporation
Law that provides that no contract between a corporation and another corporation in which one or more of its directors or officers are directors and officers or have a financial interest shall be void or voidable if the material facts are disclosed
and the board or committee in good faith authorizes the contract or transaction by the affirmative vote of the disinterested directors. Here, the disinterested directors of the Company served to overcome any potential conflict with Cash America, and
the Company respectfully submits that despite the ownership of the Company by Cash America, the disinterested approval should overcome the Staff’s concerns regarding Cash America’s control of the Company at the time the Registration
Statement was filed and the Registration Rights Agreement was entered into.

 United States Securities and Exchange Commission

Mr. Michael Clampitt

 February 10, 2015

 Page
 5

 In addition to the foregoing background on the Company’s historical relationship with
Cash America, the Company believes that the following facts and circumstances are helpful in better understanding the timeline and steps that were involved in the preparation, negotiation and approval of the separation-related agreements, the
Registration Statement and certain other documents and demonstrate that the agreements were not predetermined by Cash America, but rather, they were the result of negotiations between the Company and its advisors and Cash America and its advisors.

August 29, 2014

Cash America’s in-house legal counsel delivers drafts of the Separation and Distribution Agreement (the “Separation Agreement”), the Tax Matters Agreement and the Registration Rights Agreement to the Company’s
general counsel and certain members of the Company’s management team for their review and input.

September 4, 2014

The Company’s general counsel delivers drafts of the Separation Agreement, the Tax Matters Agreement and the Registration Rights Agreement to the Company’s outside law firm, Kirkland & Ellis LLP, seeking their comments
and input to these draft agreements.

September 7, 2014

The Company’s Director of Tax delivers to Cash America’s Vice President of Tax Administration comments to the Tax Matters Agreement.

September 8, 2014

The Company’s general counsel receives comments and proposed changes from Kirkland & Ellis LLP to the Registration Rights Agreement and the Separation Agreement and sends to Cash America’s in-house legal counsel (i)
comments and proposed changes to the Registration Rights Agreement prepared by the Company’s general counsel and Kirkland & Ellis LLP and (ii) comments and proposed changes to the Separation Agreement prepared by the Company’s general
counsel, the Company’s chief financial officer and Kirkland & Ellis LLP.

September 9, 2014

The Company’s general counsel distributes to Cash America comments and proposed changes to the Tax Matters Agreement prepared by the Company and Kirkland & Ellis LLP.

September 9, 2014

Cash America’s in-house legal counsel modifies the Registration Rights Agreement and Separation Agreement in response to proposed changes received from the Company and Kirkland & Ellis LLP and distributes revised drafts to
the Company.

 United States Securities and Exchange Commission

Mr. Michael Clampitt

 February 10, 2015

 Page
 6

September 12, 2014

Hunton & Williams LLP, Cash America’s outside counsel, modifies the Tax Matters Agreement in response to proposed changes received from the Company. Cash America’s Vice President of Tax Administration distributes a
revised draft of the Tax Matters Agreement to the Company.

September 12, 2014

The Company’s Director of Tax distributes to Cash America comments and proposed changes to the Tax Matters Agreement prepared by the Company. The Company’s Director of Tax and Cash America’s Vice President of Tax
Administration negotiate and discuss terms of the Tax Matters Agreement.

September 12, 2014

The Company’s chief financial officer and general counsel engage in discussions with Cash America’s in-house legal counsel and Hunton & Williams LLP regarding provisions in the Registration Rights Agreement and the
Separation Agreement. The Company and Cash America work to come to final agreement on the terms of the form of Registration Rights Agreement and Separation Agreement in order that the final forms of those agreements could be filed with Amendment No.
1 to the Form 10 Registration Statement (the “Form 10”). Amendment No. 1 to the Form 10, which included the forms of Registration Rights Agreement and Separation Agreement, was not filed until sign off of the forms by the
Company’s general counsel and chief financial officer.

September 15, 2014

The Company’s Director of Tax sends Cash America’s Vice President of Tax Administration proposed changes to the Tax Matters Agreement prepared by the Company and Kirkland & Ellis LLP.

September 16, 2014

The Company’s Director of Tax, Kirkland & Ellis LLP, Cash America’s Vice President of Tax Administration and Cash America’s counsel, Hunton & Williams LLP, have a conference call to discuss and negotiate
proposed changes by the Company and Kirkland & Ellis LLP to the Tax Matters Agreement.

September 20, 2014

Cash America’s in-house legal counsel delivers a draft of the Company’s Amended and Restated Certificate of Incorporation, Amended and Restated Bylaws, and Corporate Governance Principles to the Company’s general
counsel and Chief Executive Officer for their review and input.

 United States Securities and Exchange Commission

Mr. Michael Clampit

January 15, 2015

Via E -mail
David A. Fisher
President and Chief Executive Officer
Enova International, Inc.
200 West Jackson Blvd.
Chicago, IL  60606

Re: Enova International, Inc.
Amendment No. 1 to  Registration Statement on Form S -1
Filed December 5 , 2014
  File No.  333-199733

Dear Mr. Fisher :

We have limited our review of your amended registration statement and the related
response letter to those issues we have addressed in our comments.  In  some of our comments,
we may ask you to provide us with information so we may better unders tand your disclosure.

Please respond to this letter by amending your registration statement and providing the
requested information .  Where you do not believe our comments apply to your facts and
circumstances or do not believe an amendment is appropriate , please tell us why in your
response.

After reviewing any amendment to your registration statement and the information you
provide in response to these comments, we may have additional comments.

Amendment No. 1 to Registration Statement on Form S -1

1. We note your response to prior comment 2 in our letter dated November 18, 2014.  Based
on your response, we are unable to concur with your view that the subject transaction is
appropriately characterized as a secondary offering under Rule 415(a)(1)(i).  I n this
regard, we note that prior to November 13, 2014, Cash America was your parent
company and owned all of the outstanding shares of your common stock.  Given that
Cash America was your parent both at the time the instant registration statement (File
No. 333-199733) was filed on October  30, 2014 and when you and Cash America entered
into the Stockholder’s and Registration Rights Agreement on November  12, 2014, it
appears  that the transaction represents a primary offering on behalf of the Company.
Additionally, we note that pursuant to the Transition Services Agreement, dated
November  12, 2014, Cash America will provide to the Company certain services for a
transitional p eriod, including, without limitation, the maintenance of existing general
ledger accounts and the opening/closing of monthly periods.   See Schedule 1 to the

David A. Fisher
Enova International, Inc.
January 15, 2015
Page 2

 Transition Services Agreement .  Therefore, certain aspects of the offering continue to
cause us to believe that the transaction should be viewed as a primary offering on behalf
of the Company and not a secondary offering as cont emplated by Rule 415(a)(1)(i).
Please revise or advise.

Please contact David Lin at (202) 551 -3552  or me at (202) 551 -3434  with any questions.

Sincerely,

 /s/ Michael Clampitt

Michael Clampitt
Senior Counsel

cc: Via E -mail
Lisa M. Young , Esq.
L. Steven Leshin, Esq.

CORRESP
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filename1.htm

CORRESP

 HUNTON & WILLIAMS LLP

 FOUNTAIN
PLACE

 1445 ROSS AVENUE

 SUITE 3700

DALLAS, TEXAS 75202-2799

 TEL

214 • 979 • 3000

FAX

214 • 880 • 0011

 December 4, 2014

Mr. Michael Clampitt

 Senior Staff Attorney

United States Securities and Exchange Commission

 101 F Street,
NE

 Washington, D.C. 20549

Re:
Enova International, Inc.

 Registration Statement on Form S-1

Filed October 30, 2014

File No. 333-199733

 Ladies and
Gentlemen:

 On behalf of Enova International, Inc. (the “Company”), we are transmitting the following responses of the Company
to the comments of the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”), as set forth in the letter of Mr. Michael Clampitt, Senior Counsel, dated November 18, 2014 (the “Comment
Letter”), regarding the above-referenced registration statement on Form S-1 (the “Registration Statement”). The Company is filing on EDGAR these responses concurrently with the filing of Amendment No. 1 to the Registration
Statement (the “Amendment”). The Amendment incorporates changes responsive to the comments set forth in the Comment Letter. For your convenience, we have repeated each comment in italics prior to the response.

Registration Statement on Form S-1

1.
Please revise to clarify whether the offering will be conducted on a continuous or delayed basis. In this regard, we note that the cover page of the registration statement indicates that the offering will be
commenced “[a]s soon as practicable after this registration statement becomes effective.” However, the cover page of the prospectus indicates that your “registration of the shares of common stock covered by this prospectus does not
mean that Cash America will offer or sell any of the shares.” Please revise to reconcile and clarify your disclosure, as appropriate.

 United States Securities and Exchange Commission

Mr. Michael Clampitt

 December 4, 2014

 Page
 2

 Company Response:

The offering will be conducted on a continuous or delayed basis. In response to the Staff’s comment, the Company has deleted the sentence
on the cover page of the prospectus that indicates that our “registration of the shares of common stock covered by this prospectus does not mean that Cash America will offer or sell any of the shares” in order to reconcile and clarify the
disclosure.

2.
Given the nature of Cash America’s relationship to you, it appears possible that these securities are being offered by or on behalf of the registrant. We also note that you are not eligible to make an
at-the-market offering under Rule 415(a)(4) under the Securities Act because you are not eligible to make an offering under Rule 415(a)(1)(x). Please provide us with a detailed analysis as to why the proposed offering is not a primary offering on
your behalf and thus should be appropriately characterized as a secondary offering eligible to be made pursuant to Rule 415(a)(1)(i), including in such analysis a detailed description of the relationship between you and Cash America, an analysis of
whether Cash America is your parent and affiliate, and the other factors set forth in Securities Act Rules Compliance and Disclosure Interpretation 612.09. Please also address in your analysis the fact that one of your directors, Daniel R. Feehan,
is the President and Chief Executive Officer of Cash America as well as the various operating and other agreements (see pages 55 - 62) in effect now or contemplated in the future. Also, address the debt guarantees. Please also refer to Question
212.15 of our Compliance & Disclosure Interpretations for Securities Act Rules for guidance.

 Company
Response:

 For the reasons discussed below, the Company respectfully submits to the Staff that the offering (the “Offering”)
of shares of common stock of the Company by Cash America International, Inc. (“Cash America”) pursuant to the Registration Statement (the “Shares”) should be viewed as a secondary offering as contemplated by Rule 415(a)(1)(i) and
not as a primary offering on behalf of the Company.

 United States Securities and Exchange Commission

Mr. Michael Clampitt

 December 4, 2014

 Page
 3

 Background

Set forth below are facts relevant to the analysis that follows and a detailed description of the relationship between the Company and Cash
America.

 Formation of the Company and Acquisition of the Shares. On September 7, 2011, Cash America formed the Company
under the laws of Delaware. Six days later, on September 13, 2011, Cash America contributed to the Company all of the entities through which Cash America conducted its e-commerce business in exchange for all of the Company’s issued and
outstanding common stock in an internal tax-free transfer. Cash America first entered into the e-commerce business on September 15, 2006 through its purchase of the assets of The Check Giant, LLC, an unrelated party, for $255.2 million.

The Spin-off. On October 22, 2014, the Board of Directors of Cash America approved a tax-free distribution of approximately
80% of the Company’s issued and outstanding common stock to Cash America’s shareholders (the “Spin-off”). On November 13, 2014, the Spin-Off was completed. Cash America retained 20% of the Company’s common stock in
connection with the Spin-off, and it is these shares that are to be covered by the Registration Statement. Following the Spin-off, Enova continues the active conduct of its e-commerce business, independently from Cash America and with its separate
management and employees.

 The Company’s shares of common stock were registered under the Securities Exchange Act of 1934, as amended
(the “Exchange Act”), in October 2014 in connection with the Spin-off and are listed and actively traded on the New York Stock Exchange. The Company’s public float consists of approximately 80% of the Company’s issued and
outstanding common stock.

 The Private Letter Ruling from the Internal Revenue Service Relating to Cash America’s Retention of
the Shares and Related Control Restrictions. The Spin-off was effected in a manner intended to qualify as a tax-free distribution so that Cash America’s shareholders receiving shares of the Company’s common stock in the Spin-off
would not recognize gain or loss under federal income tax laws upon receipt of the shares. To qualify for nontaxable treatment under section 355 of the Internal Revenue Code, among other requirements, Cash America was required to distribute an
amount of stock of the Company to Cash America’s shareholders constituting “control” of the Company within the meaning of section 368(c) of the Internal Revenue Code. Because Cash America intended to retain 20% of the Company’s
outstanding common stock, section 355(a)(1)(D)(ii) of the Internal Revenue Code required that Cash America establish to the satisfaction of the Internal Revenue Service (“IRS”) that its retention of the Shares was not in pursuance of a
plan having as one of its principal purposes the avoidance of federal income tax. In order to meet this requirement, Cash America requested, and received on October 10, 2014, a private letter ruling (“PLR”) from the IRS ruling that
the retention of the Shares by Cash America met this requirement for nontaxable treatment of the Spin-off. This PLR was based upon actions to be taken by Cash America and specific representations made by Cash America to the IRS to satisfy IRS
requirements for the issuance of the PLR.

 United States Securities and Exchange Commission

Mr. Michael Clampitt

 December 4, 2014

 Page
 4

 Specifically, Cash America represented to the IRS that Cash America would vote the Shares
that it retained in proportion to the votes cast by the Company’s other stockholders on matters submitted to a vote of stockholders and would grant the Company a proxy to vote the Shares in proportion to the votes cast by the Company’s
other stockholders. Pursuant to a Stockholder’s and Registration Rights Agreement between Cash America and the Company, Cash America granted a proxy to the Company to vote the Shares of common stock retained by Cash America in proportion to the
votes cast by the Company’s other stockholders.1 As such, Cash America no longer possesses the voting power over any shares of the Company’s common stock.

Cash America also represented to the IRS that Cash America and the Company will operate as independent companies having separate boards of
directors, and to the extent that they interact with each other, they would do so under commercially reasonable terms similar to those that would be agreed to by third parties negotiating at arm’s-length. Cash America further represented that
the separate boards of directors will have no overlapping members, with the exception of Daniel R. Feehan, Cash America’s chief executive officer (“CEO”) and president, who could serve as a director of both corporations for a
transitional period not to exceed two years following the Spin-off to accommodate needs of the Company, as discussed below under “The Company’s Board of Directors and Officers.”2

 The PLR also requires that, with the potential exception of a small portion of the Shares reserved to settle certain restricted stock
unit awards and deferred director equity-based compensation (representing approximately 2% of the Company’s outstanding shares), the Shares retained by Cash America will be sold by Cash America not later than two years after the Spin-off.

1
The proxy will terminate as to shares upon the sale or transfer of such shares from Cash America to any other person.

2
The PLR provides that Mr. Feehan will be eligible to serve on the Company’s Board of Directors after this two year transitional period if he is no longer serving as an executive officer of Cash America.

 United States Securities and Exchange Commission

Mr. Michael Clampitt

 December 4, 2014

 Page
 5

 These foregoing requirements that Cash America agreed to with the IRS based on these
representations are referred as the “IRS Control Restrictions.” The Company has been informed by Cash America that Cash America intends to comply with these IRS Control Restrictions since, if it fails to do so, it could invalidate the PLR
and jeopardize the tax-free treatment of the Spin-off.

 The Separation-Related Agreements. As part of the separation and
distribution, the Company and Cash America entered into the following agreements (the “Separation-Related Agreements”):

•

Separation and Distribution Agreement. The Separation and Distribution Agreement governed the terms of the separation of the Company from Cash America. This agreement contains Cash America’s and the
Company’s agreements relating to the restructuring steps taken to complete the Spin-off, including the assets, equity interests and rights to be transferred, liabilities to be assumed, contracts to be assigned, mutual releases, indemnities,
agreements as to insurance following the Spin-off and related matters. This agreement also specified the conditions that were required to be satisfied prior to the Spin-off and contains certain post-Spin-off obligations of both the Company and Cash
America.

•

Tax Matters Agreement. As a result of the Spin-off, the Company and its subsidiaries ceased to be members of the affiliated group (as that term is defined in the Internal Revenue Code) of which Cash America was
the common parent, a so-called tax deconsolidation. The Tax Matters Agreement governs Cash America’s and the Company’s respective rights, responsibilities and obligations with respect to taxes, tax attributes, tax returns, tax contests and
certain other tax matters.

•

Stockholder’s and Registration Rights Agreement. Under the Stockholder’s and Registration Rights Agreement, Cash America agreed to vote the Shares that it retained in proportion to the votes cast by the
Company’s other stockholders on matters submitted to a vote of stockholders and granted a proxy to the Company to vote the Shares in proportion to the votes cast by the Company’s other stockholders. In addition, the Company agreed to use
its best efforts to register the Shares retained by Cash America to the extent such shares are not registered and sold pursuant to the Registration Statement.

 United States Securities and Exchange Commission

Mr. Michael Clampitt

 December 4, 2014

 Page
 6

•

Transition Services Agreement. Pursuant to the Transition Services Agreement, Cash America agreed to provide the Company, on a transitional basis, certain information systems support generally consistent with
similar services provided by Cash America to the Company before the Spin-off at a fee of $18,000 per month plus reimbursement of Cash America’s out-of-pocket expenses. This fee is intended to allow Cash America to recover the costs directly
associated with providing these services, with nominal profit. The Company expects that it will complete the transition of these services on or before 12 months following the Spin-off.

•

Software Lease and Maintenance Agreement. Pursuant to the Software Lease and Maintenance Agreement, the Company leased a version of its consumer loan underwriting model for use by Cash America in its consumer
credit business and provides maintenance, and Cash America agreed to pay the Company lease and maintenance fees.

 Critical
to the tax-free treatment and the continued validity of the PLR, the post-spin relationships of Cash America and the Company may not be tantamount to continued control of the Company by Cash America. None of these Separation-Related Agreements grant
Cash America the power to direct or cause the direction of the management and policies of the Company or grant any rights permitting Cash America to participate in the management or day-to-day operations of the Company’s business nor do they
grant Cash America indicia of control of the Company since doing so would conflict with requirements for the tax-free treatment of the Spin-off and jeopardize tax-free treatment.

Further, in connection with the Spin-off, all guarantees by the Company of Cash America’s indebtedness were released, and the Company is
not an obligor or guarantor of any Cash America indebtedness. In addition, Cash America is not an obligor or guarantor of any of the Company’s indebtedness (although, as further discussed below, Cash America’s guaranty of the
Company’s lease obligations on its present headquarters lease has not been released by the landlord and as such, Cash America’s guaranty will remain in place likely until in 2017 when the lease term expires). Approximately six months prior
to the Spin-off, the Company repaid all intercompany indebtedness owed to Cash America. There are not any financing agreements between Cash America and the Company. Each of the company’s financing arrangements is independent of each other.

The Company does not currently intend to enter into any other agreements with Cash America.

 United States Securities and Exchange Commission

Mr. Michael Clampitt

 December 4, 2014

 Page
 7

 The Company’s Board of Directors and Officers. Cash America does not have
the right, whether by contract or otherwise, to elect any members of the Company’s Board of Directors. The Board of Directors of the Company consists of seven members, five of whom are outside, independent directors, one of whom is the
Company’s Chief Executive Officer and the other is Mr. Feehan, Cash America’s CEO. The five outside, independent directors have no relationship or prior involvement or business dealings with Cash America. The Company expects that
Mr. Feehan will serve on the Company’s Board of Directors during a transitional period not to exceed two years from the date of the Spin-off to accommodate the Company’s need for his unique industry experience, to leverage his
well-developed relationships with banking and regulatory groups, and to provide a sense of business continuity. Mr. Feehan will stand for re-election as a director by the Company’s stockholders along with all of the Compa

November 18, 2014

Via E -mail
David A. Fisher
President and Chief Executive Officer
Enova International, Inc.
200 West Jackson Blvd.
Chicago, IL  60606

Re: Enova International, Inc.
Registration Statement on Form S -1
Filed October 30, 2014
  File No.  333-199733

Dear Mr. Fisher :

We have limited our review of your registration statement to those issues we have
addressed in our comments.  In  some of our comments, we may ask you to provide us with
information so we may better understand your disclosure.

Please respond to this letter  by amending your registration statement and providing the
requested information .  Where you do not believe our comments apply to your facts and
circumstances or do not believe an amendment is appropriate, please tell us why in your
response.

After revi ewing any amendment to your registration statement and the information you
provide in response to these comments, we may have additional comments.

Registration Statement on Form S -1

1. Please revise to clarify whether the offering will be conducted on a c ontinuous or delayed
basis.  In this regard, we note that the cover page of the registration statement indicates
that the offering will be commenced “[a]s soon as practicable after this registration
statement becomes effective.”  However, the cover page of  the prospectus indicates that
your “registration of the shares of common stock covered by this prospectus does not
mean that Cash America will offer or sell any of the shares.”  Please revise to reconcile
and clarify your disclosure, as appropriate.

2. Give n the nature of Cash America’s relationship to you, it appears possible that these
securities are being offered by or on behalf of the registrant.   We also note that you are
not eligible to make an at -the-market offering under Rule 415(a)(4) under the Sec urities
Act because you are not eligible to make an offering under Rule 415(a)(1)(x).   Please
provide us with a detailed analysis as to why the proposed offering is not a primary

David A. Fisher
Enova International, Inc.
November 18, 2014
Page 2

 offering on your behalf and thus should be appropriately characterized as a secondary
offering eligible to be made pursuant to Rule 415(a)(1)(i), including in such analysis a
detailed description of the relationship between you and Cash America, an analysis of
whether Cash America is your parent and affiliate, and the other factor s set forth in
Securities Act Rules Compliance and Disclosure Interpretation 612.09.  Please also
address in your analysis the fact that one of your directors, Daniel R. Feehan, is the
President and Chief Executive Officer of Cash America as well as the va rious operating
and other agreements (see pages 55 - 62) in effect now or contemplated in the future.
Also, address the debt guarantees.  Please also refer to Question 212.15 of our
Compliance & Disclosure Interpretations for Securities Act Rules for guid ance.

Part II.

Item 17. Undertakings, page II -3

3. Please provide all the appropriate undertakings required by Item 512 of Regulation S -K
that apply.  Specifically, it appears that Rule 430C of the Securities Act of 1933 may be
applicable and the undertak ings required by Item 512(a)(5)(ii) of Regulation S -K should
be included.  Please revise or advise.

We urge all persons who are responsible for the accuracy and adequacy of the disclosure
in the filing to be certain that the filing includes the informat ion the Securities Act of 193 3 and
all applicable Securities  Act rules require.   Since the company and its management are in
possession of all facts relating to a company’s disclosure, they are responsible for the accuracy
and adequacy of the disclosures t hey have made.

Notwithstanding our comments, in the event you request acceleration of the effective date
of the pending registration statement please provide a written statement from the company
acknowledging that:

 should the Commission or the staff, acting pursuant to delegated authority, declare the
filing effective, it does not foreclose the Commission from taking any action with respect
to the filing;

 the action of the Commission or the staff, acting pursuant t o delegated authority, in
declaring the filing effective, does not relieve the company from its full responsibility for
the adequacy and accuracy of the disclosure in the filing; and

 the company may not assert staff comments and the declaration of effect iveness as a
defense in any proceeding initiated by the Commission or any person under the federal
securities laws of the United States.

Please refer to Rules 460 and 461 regarding requests for  acceleration .  We will consider a
written request for acceler ation of the effective date of the registration statement as confirmation

David A. Fisher
Enova International, Inc.
November 18, 2014
Page 3

 of the fact that those requesting acceleration are aware of their respective responsibilities under
the Securities Act of 1933 and the Securities Exchange Act of 1934 as they relate to the proposed
public offering of the securities specified in the above registration statement.  Please allow
adequate time  for us to review any amendment prior to the requested effective date of the
registration statement.

Please contact David Lin at (202) 551 -3552  or me at (202) 551 -3434  with any questions.

Sincerely,

 /s/ Michael Clampitt

Michael Clampitt
Senior Counsel

cc: Via E -mail
Lisa M. Young , Esq.
L. Steven Leshin, Esq.

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 200 W Jackson Blvd, Suite 2400

 Chicago, IL
60606

 T 1.312.568.4200

enova.com

 October 22, 2014

Mr. Michael Clampitt

VIA EDGAR

 Senior Staff Attorney

 United States Securities and Exchange Commission

 Division of Corporate Finance

 101 F Street, NE

 Washington, DC 20549

Re:
Enova International, Inc.

 Registration Statement on Form 10 (File
No. 001-35503)

 Dear Mr. Clampitt:

Reference is made to the Registration Statement on Form 10 (File No. 001-35503) (as amended, the “Registration Statement”),
filed by Enova International, Inc. (the “Company”) with the U.S. Securities and Exchange Commission (the “Commission”).

Cash America International, Inc. (“Cash America”) set November 3, 2014 as the record date for the distribution of the shares of
common stock of the Company (the “Shares”), which is scheduled to occur on November 13, 2014. Cash America and the Company would like for the Shares to commence trading on the New York Stock Exchange on a “when issued” basis
as soon as practicable and potentially as early as October 30, 2014, two business days prior to the record date. Accordingly, the Company hereby requests that the effective date for the Registration Statement be accelerated to 2:00 p.m.,
Eastern time, on October 24, 2014, or as soon as practicable thereafter, pursuant to Section 12(d) of the U.S. Securities Exchange Act of 1934, as amended, and Rule 12d1-2 thereunder.

The Company acknowledges that the adequacy and accuracy of the disclosure in the Registration Statement is the responsibility of the Company.
The Company further acknowledges that:

•

Should the Commission or the staff of the Commission (the “Staff”), acting pursuant to delegated authority, declare the filing effective, it does not foreclose the Commission from taking any action with
respect to the filing;

•

The action of the Commission or the Staff, acting pursuant to delegated authority, in declaring the filing effective, does not relieve the Company from its full responsibility for the adequacy and accuracy of the
disclosure in the filing; and

•

The Company may not assert the Staff comments and the declaration of effectiveness as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.

 Please contact the undersigned at (312) 676-1591 with any questions you may have concerning this request. Upon grant
of our request to accelerate effectiveness, we would appreciate your communicating to the Company’s counsel, L. Steven Leshin, via telephone at (214) 468-3348, or Lindsay Ferguson, via telephone at (214) 468-3343, confirmation of the
exact time at which the Registration Statement was declared effective.

Very truly yours,

ENOVA INTERNATIONAL, INC.

By:

/s/ Lisa M. Young

Lisa M. Young

Vice President—General Counsel & Secretary

cc:
J. Curtis Linscott, Esq.

 Wendy W. Walton, Esq.

L. Steven Leshin, Esq.

 Lindsay
H. Ferguson, Esq.

September 23 , 2014

Via E -mail
Lisa M. Young
Vice President – General Counsel & Secretary
Enova International, Inc.
200 W est Jackson Boulevard
Chicago, Illinois 60606

Re: Enova International, Inc.
   Amendment No. 1 to Registration Statement on Form  10
Filed September 12, 2014
  File No. 001-35503

Dear Ms . Young :

We have reviewed your filing and have the following comments.   In some of our
comments, we may ask you to provide us with information so we may better understand your
disclosure.

Please respond to this letter within ten business days by amending your filing, by
providing the requested information, or by advising us  when you will provide the requested
response.  If you do not believe our comments apply to your facts and circumstances or do not
believe an amendment is appropriate, please tell us why in your response.

After reviewing any amendment to your filing and t he information you provide in
response to these comments, we may have additional comments.

Amendment No. 1 to Registration Statement on Form 10  filed September 12, 2014

General

1. We note your response to Comment 3 in our letter dated August 26, 2014.  The  staff’s
position is that the information in Exhibit 99.1 does not meet the requirements of Rule 12b -
32 of the Exchange Act rules and Item 10(d) of Regulation S -K unless it is filed by Cash
America.  Please revise to add the  specific information for each f orm item.

Lisa M. Young
Enova International, Inc.
September 23, 2014
Page 2

 Exhibit 99.1

Current and Delinquent Consumer Loans, page 95

2. We note your response to Comment 6  from our letter dated August 26, 2014.  Please revise
your filing to include the quantitative information provided in your response as a footnote to
your consumer loan portfolio receivable tables disclosed on pages F -16 and F -42 through F -
43 so that the composition of your delinquent loans is clearly disclosed.   Specifically,
separately disclose the amounts of both loans on non -accrual stat us and payment amounts
classified as delinquent which together comprise delinquent loans.

We urge all persons who are responsible for the accuracy and adequacy of the disclosure
in the filing to be certain that the filing includes the information the Securities Exchange Act of
1934 and all applicable Exchange Act rules require.   Since the company and its management are
in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy
and adequacy of the disclosures th ey have made.

In responding to our comments, please provide a written statement from the company
acknowledging that:

 the company is responsible for the adequacy and accuracy of the disclosure in the filing;

 staff comments or changes to disclosure in response to staff comments do not foreclose
the Commission from taking any action with respect to the filing; and

 the company may not assert staff comments as a defense in any proceeding initiated by
the Commission or any person under the federal securit ies laws of the United States.

You may contact John Spitz  at (202) 551 -3484  or Amit Pande  at (202) 551 -3423  if you
have questions regarding comments on the financial statements and related matters.  Please
contact Josh Samples  at (202) 551 -3199  or me at (202) 551 -3434 with any other questions.

Sincerely,

 /s/ Michael Clampitt

Michael Clampitt
Senior Staff Attorney

cc. Via E -mail
 Lindsay Ferguson
Hunton & Williams LLP

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 HUNTON & WILLIAMS LLP

 FOUNTAIN PLACE

1445 ROSS AVENUE

 SUITE 3700

DALLAS, TEXAS 75202-2799

TEL 214 • 979 • 3000

 FAX 214 • 880 •
0011

 September 12, 2014

Mr. Michael Clampitt

 Senior Staff Attorney

United States Securities and Exchange Commission

 101 F Street,
NE

 Washington, D.C. 20549

Re:
Enova International, Inc.

 Registration Statement on Form 10

Filed July 31, 2014

File No. 001-35503

 Ladies and
Gentlemen:

 On behalf of Enova International, Inc. (the “Company”), we are transmitting the following responses of the Company
to the comments of the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”), as set forth in the letter of Mr. Michael Clampitt, Senior Staff Attorney, dated August 26, 2014 (the
“Comment Letter”), regarding the above-referenced registration statement on Form 10 (the “Form 10”). The Company is filing on EDGAR these responses concurrently with the filing of Amendment No. 1 to the Form 10 (the
“Amendment”). The Amendment incorporates changes responsive to the comments set forth in the Comment Letter. For your convenience, we have repeated each comment in italics prior to the response.

The references to page numbers in the headings are to the original information statement filed as Exhibit 99.1 to the Form 10, and all
references to page numbers in the Company’s responses below are to the information statement filed as Exhibit 99.1 to the Amendment.

 Exhibit
99.1

 General

1.
Please note that the Form 10 goes effective by lapse of time 60 days after the date filed pursuant to Section 12(g)(1) of the Securities Exchange Act of 1934. After that date, you will be subject to the
reporting requirements under Section 13(a) of the Securities Exchange Act of 1934. In addition, we will continue to review your filing until all of our comments have been addressed.

 United States Securities and Exchange Commission

Mr. Michael Clampitt

 September 12, 2014

 Page
 2

 Company Response:

The Company’s Form 10 was filed pursuant to Section 12(b) of the Securities Exchange Act of 1934 (“Exchange Act”). As a
result, as we have discussed with the Staff, the Form 10 will become effective, in accordance with Section 12(d) of the Exchange Act, 30 days (unless declared effective prior to such date) from the date the New York Stock Exchange
(“NYSE”) certifies that the Company’s securities have been approved for listing, rather than under Section 12(g)(1).

2.
Please revise the Form 10 to include the information that is currently incorporated by reference. The Exhibit 99.1 is not able to be incorporated unless previously filed. See Item 10(d) of Regulation S-K.

 Company Response:

The Company has revised the Form 10 to clarify that the information statement contained as Exhibit 99.1 is not incorporated by reference into
the Form 10. As revised, only information from specified sections of the information statement is now incorporated by reference into the Form 10. The Company believes that the incorporation of specified information from identified sections of the
information statement is permitted by Exchange Act Rule 12b-23, which provides that “. . . information may be incorporated by reference in answer, or partial answer, to any item of a registration statement or report,” provided, among
other things, “[i]nformation in any part of the registration statement or report may be incorporated by reference in answer, or partial answer, to any other item of the registration statement or report.” Since the information statement is
filed as Exhibit 99.1 to the Form 10 and is part of the registration statement, the Company respectfully advises the Staff that it believes that it is eligible to incorporate by reference specific information contained in the information statement
filed as part of the registration statement in answer to an item of the Form 10 in accordance with Exchange Act Rule 12b-23.

 United States Securities and Exchange Commission

Mr. Michael Clampitt

 September 12, 2014

 Page
 3

3.
We note that Cash America’s information statement was filed as an exhibit to Enova’s Form 10. Cash America should either file the information statement on Schedule 14C or provide the staff with an analysis
as to why a separate filing is not required. You may refer to Staff Legal Bulletin No. 4 for further guidance. Please note that, once the Schedule 14C is filed, the staff may have additional comments specifically related to that filing.

 Company Response:

The Company respectfully submits that a filing of the information statement by Cash America International, Inc. (“Cash America”) on
Schedule 14C is not required because Section 14(c) of the Exchange Act does not require such filing. Section 14(c) of the Exchange Act provides:

Unless proxies, consents, or authorizations in respect of a security registered pursuant to Section 12 of this title, or a security
issued by an investment company registered under the Investment Company Act of 1940, are solicited by or on behalf of the management of the issuer from the holders of record of such security in accordance with the rules and regulations prescribed
under subsection (a) of this section, prior to any annual or other meeting of the holders of such security, such issuer shall, in accordance with rules and regulations prescribed by the Commission, file with the Commission and transmit
to all holders of record of such security information substantially equivalent to the information which would be required to be transmitted if a solicitation were made . . . (emphasis added)

Similarly, Rule 14c-2 of Schedule 14C of the Exchange Act provides:

(a)(1) In connection with every annual or other meeting of the holders of the class of securities registered pursuant to section 12 of the
Act or of a class of securities issued by an investment company registered under the Investment Company Act of 1940 that has made a public offering of securities, including the taking of corporate action by the written authorization or consent
of security holders, the registrant shall transmit to every security holder of the class that is entitled to vote or give an authorization or consent in regard to any matter to be acted upon and from whom proxy authorization or consent is not
solicited on behalf of the registrant pursuant to section 14(a) of the Act: (i) A written information statement containing the information specified in Schedule 14C . . . (emphasis added)

 United States Securities and Exchange Commission

Mr. Michael Clampitt

 September 12, 2014

 Page
 4

 The Company understands that Section 14(c) of the Exchange Act and Rule 14c-2 of
Schedule 14C require that if there is to be a meeting of shareholders, including taking of corporate action by written consent, and proxies are not solicited under Section 14(a) of the Exchange Act by the registrant for action to be taken at
the meeting, before action can be taken by shareholders at the meeting, the registrant must deliver an information statement on Schedule 14C to the shareholders. That is not the case here.

Cash America is a Texas corporation and is governed by the Texas Business Organizations Code (“TBOC”). Under Section 21.455(a)
of the TBOC, a sale, transfer, assignment or other conveyance does not require the approval or consent of the shareholders of a Texas corporation, such as Cash America, “unless the transaction constitutes a sale of all or substantially all of
the assets of the corporation.” In turn, the phrase “sale of all or substantially all of the assets” is defined narrowly in Section 21.451(2) of the TBOC. The definition of “sale of all or substantially all of the
assets” expressly states that “the term [sale of all or substantially all of the assets] does not include a transaction that results in the corporation directly or indirectly: (A) continuing to engage in one or more businesses.”
Because Cash America will continue to engage in its retail store-front pawn and lending businesses after the distribution, the distribution is not a “sale of all or substantially all of the assets” of Cash America under Texas law. That
being the case, under Section 21.455(a) of the TBOC, no shareholder action or consent is required and none is being taken in connection with the distribution. The distribution will be authorized by the Board of Directors of Cash America, alone.

 Because the distribution does not require a shareholder vote or written consent in lieu of a shareholder vote under the TBOC to authorize
the distribution, the Company respectfully submits that the provisions of Section 14(c) of the Exchange Act and Rule 14c-2 of Schedule 14C do not require the filing of an information statement on Schedule 14C by Cash America. The fact that
no vote of the Cash America shareholders is required in connection with the distribution is disclosed in the information statement. For example, this is disclosed on page (i) of the information statement filed as Exhibit 99.1 to the Form 10.

 United States Securities and Exchange Commission

Mr. Michael Clampitt

 September 12, 2014

 Page
 5

 Consistent with this analysis, shareholder approval has not been sought in significant
spin-offs by Delaware companies when, like Texas, there is law to support the determination that a spin-off does not constitute a sale, lease or exchange of all or substantially all of the assets of a corporation, and therefore, no shareholder
approval is required. For example, none of the following significant spin-off transactions listed below sought shareholder approval in connection with these spin-off transactions nor filed an information statement on Schedule 14C.

•

Tribune Company’s spin-off of Tribune Publishing Company (File No. 001-36230) (Form 10 originally filed December 9, 2013 and certification from NYSE received by the Commission on July 21, 2014);

•

Time Warner Inc.’s spin-off of Time Inc. (File No. 001-36218) (Form 10 originally filed November 22, 2013 and certification from NYSE received by the Commission on May 9, 2014);

•

Simon Property Group, Inc.’s spin-off of SPG SpinCo Subsidiary Inc. (File No. 001-36252) (Form 10 originally filed December 24, 2013 and certification from NYSE received by the Commission on May 6, 2014);

•

Sears Holdings Corporation’s spin-off of Lands’ End, Inc. (File No. 001-09769) (Form 10 originally filed December 6, 2013 and certification from The Nasdaq Stock Market received by the Commission on March 18,
2014); and

•

Valero Energy Corporation’s spin-off of Corner Store Holdings, Inc. (File No. 001-35743) (Form 10 originally filed November 16, 2012 and certification from NYSE received by the Commission on April 9, 2013).

 The Company has reviewed Staff Legal Bulletin No. 4 (“SLAB No. 4”) and understands that it provides
five conditions under which a spin-off transaction does not require registration under the Securities Act of 1933. One of those conditions is adequacy of public information that describes the spin-off and the subsidiary, and that requirement is met,
according to the SLAB No. 4, if the distributing company delivers to its shareholders, by the date it spins-off the securities, an information statement that substantially complies with Regulation 14A or Regulation 14C under the Exchange Act.
While SLAB No. 4 requires that the information statement substantially comply with Regulation 14A or 14C, SLAB No. 4 does not require that such an information statement be filed on Schedule 14C under Regulation 14C. The information
statement contained in the Company’s Form 10 substantially complies with Regulation 14C as contemplated by SLAB No. 4 and, as discussed in the information statement, the information statement will be mailed to all of Cash America’s
shareholders as of the record date.

 In summary, the Company respectfully submits that Cash America is not required to make a separate
filing on Schedule 14C because such a filing is not required by Section 14(c) or Rule 14c-2 of the Exchange Act and the information statement (which substantially complies with Regulation 14C) will be mailed to all of Cash America’s
shareholders as of the record date in compliance with the requirements of SLAB No. 4.

 Risk Factors, page 25

4.
Some of your risk factors state that you cannot provide assurance of a certain outcome when the real risk is not your inability to provide assurance, but the underlying situation. Please revise this and similar
language to describe the real risks of the transaction.

 Company Response:

The Company has revised the risk factors and similar language in the Amendment to address the Staff’s comment.

 United States Securities and Exchange Commission

Mr. Michael Clampitt

 September 12, 2014

 Page
 6

 Basis of Presentation and Critical Accounting Policies, page 94

5.
We note your allowance for loan loss accounting policy disclosure on page 96. Please tell us and revise your filing to explain in further detail the discrete groups that your outstanding loans are divided into for
purposes of determining your allowance for loan losses. To the extent that these discrete loan groups are a further disaggregation of your short-term loans, installment loans and line of credit accounts, please include an enhanced discussion of how
such disaggregation is used to determine your allowance for loan losses.

 Company Response:

In the information statement, the Company has described its methodology used to estimate the allowance for loan losses by portfolio segment, as
required by Accounting Standards Codification (“ASC”) 310-10-50-11a, Receivables – Overall – Disclosure – Allowance for Credit Losses Related to Financing Receivables. The Company’s appropriate portfolio segments
are short-term loans, line of credit accounts and installment loans.

 In order to calculate the allowance or liability for estimated losses
on the Company’s consumer loan portfolio, the Company initially disaggregates its consumer loan portfolio primarily by loan product (short-term loans, installment loans and line of credit accounts) due to the different characteristics of the
products and reserve methodologies. The Company believes that disaggregating the portfolio into these discrete loan groups is the appropriate level for monitoring loan performance and is aligned with their underwriting differences. For each discrete
loan group, reserve rates are derived from the loan performance data and applied against consumer loans outstanding at each period end to arrive at the appropriate allowance and liability balance for estimated losses on consumer loans.

While the Company may further evaluate the loan performance data by functional currency or brand, if applicable, to calculate the allowance or
liability for estimated loan losses, the Company follows the same methodology in each product group (short-term loans, installment loans and line of credit accounts), even if those product groups are further evaluated by country or brand.

 United States Securities and Exchange Commission

Mr. Michael Clampitt

 September 12, 2014

 Page
 7

 Current and Delinquent Customer Accounts, page 95

6.
We note your disclosure that for one missed payment, only that payment is considered delinquent for an installment loan or line of credit. We also note that for two consecutive missed payments, the entire loan or
account is classified delinquent. Please quantify for us the installment loans and lines of credit total loan balances that are delinquent only one payment as of each period end presented.

Company Response:

 The
amounts of installment loans and line of credit account balances that are delinquent only one payment for each balance sheet date presented in the information statement are as follows:

 (in thousands)

June 30,
2014

December 31,
2013

June 30,
2013

December 31,
2012

 Payment Amounts Classified as Delinquent (One Delinquent Payment)

$
5,372

$
5,870

$
2,575

$
2,196

 Remaining Balance Classified as Current

16

August 26, 2014

Via E -mail
Lisa M. Young
Vice President – General Counsel & Secretary
Enova International, Inc.
200 W est Jackson Boulevard
Chicago, Illinois 60606

Re: Enova International, Inc.
   Registration Statement on Form  10
July 31, 2014
  File No. 001-35503

Dear Ms . Young :

We have reviewed your filing and have the following comments.   In some of our
comments, we may ask you to provide us with information so we may better understand your
disclosure.

Please respond to this letter within ten business days by amending your filing, by
providing the requested information, or by advising us  when you will provide the requested
response.  If you do not believe our comments apply to your facts and circumstances or do not
believe an amendment is appropriate, please tell us why in your response.

After reviewing any amendment to your filing and t he information you provide in
response to these comments, we may have additional comments.

Registration Statement on Form 10  filed July 31, 2014

Exhibit 99.1

General

1. Please note that the Form 10 goes effective by lapse of time 60 days after the date fi led
pursuant to Section 12(g)(1) of the Securities Exchange Act of 1934.  After that date, you
will be subject to the reporting requirements under Section 13(a) of the Securities Exchange
Act of 1934.  In addition, we will continue to review your filing  until all of our comments
have been addressed.

2. Please revise the Form 10 to include the information that is currently incorporated by
reference.  The Exhibit  99.1 is not able to be incorporated unless previously filed.   See Item
10(d) of Regulation S -K.

Lisa M. Young
Enova International, Inc.
August 26, 2014
Page 2

 3. We note that Cash America’s information statement was filed as an exhibit to Enova’s Form
10.  Cash America should either file the information statement on Schedule 14C or provide
the staff  with an analysis as to why a separate filing is not required.  You may refer to Staff
Legal Bulletin No. 4 for further guidance.  Please note that, once the Schedule 14C is filed,
the staff may have additional comments specifically related to that filing.

Risk Factors, page 25

4. Some of your risk factors state that you cannot provide assurance of a certain outcome when
the real risk is not your inability to provide assurance, but the underlying situation.  Please
revise this and similar language to describe the real risks of the transaction.

Basis of Presentation and Cr itical Accounting Policies, page 94

5. We note your allowance for loan loss accounting policy disclosure on page 96.  Please tell us
and revise your filing to explain in further detail the discrete groups that your outstanding
loans are divided into for purp oses of determining your allowance for loan losses. To the
extent that these discrete loan groups are a further disaggregation of your short -term loans,
installment loans and line of credit accounts, please include an enhanced discussion of how
such disagg regation is used to determine your allowance for loan losses.

Current and Delinquent Consumer Accounts, page 95

6. We note your disclosure that for one missed payment, only that payment is considered
delinquent for an installment loan or line of credit. We  also note that for two consecutive
missed payments, the entire loan or account is classified delinquent. Please quantify for us
the installment loans and lines of credit total loan balances that are delinquent only one
payment as of each period end presen ted.

7. We also note disclosure that in some instances customers agree to repay a new short -term
loan in two or three payments, in which you have determined that the initial payment is a
new loan with the remaining payments considered renewals or extension s with separate
finance charges due at the time of each payment.  Please tell us and revise your filing to
address the following:

 Quantify your short -term loans with these terms as of both June 30, 2014 and December
31, 2013;
 Provide a discussion of the a mount of finance charges for each payment made and how
these compare to other finance charges for short -term loans which do not have these
payment terms; and
 Tell us in further detail why you consider subsequent payments under these loan terms to
represent  renewals or extensions and provide the authoritative guidance you relied upon.

Lisa M. Young
Enova International, Inc.
August 26, 2014
Page 3

 Business

Proprietary Data, Models and Underwriting, page 144

8. We note your discussion of the various factors that are considered when evaluating whether
to extend credit to a potential customer.  To the extent certain factors are weighted more
heavily than others, please disclose such factors and their overall weight in the evaluation.
Additionally, to the extent known, please disclose the averages for each significant facto r
under “Our Customers” on page 139.  For example, if FICO scores are considered a
significant factor, state as much under this section and disclose the average FICO score under
“Our Customers.”

Compensation Discussion and Analysis

Summary Compensation Table, page 180

9. In footnote 7, we note that you represent that, “[e]xcept as noted below with respect to Mr.
Ho, none of the other individual amounts exceed $25,000. ”  Please also include a
representation that no other individual amounts exceed 10% of the  total amount of
perquisites and personal benefits for each individual, as required by Instruction 4 to Item
402(c)(2)(ix) of Regulation S -K.

Audited Financial Statements

Note 3. Consumer Loans, Credit Quality Information and Allowances and Liabilities for
Estimated Losses, page F -16

10. Please revise your filing to provide the following disclosures required by ASU 2010 -20
(ASC 310 -10-50):

 Confirm whether your delinquent loans are considered nonaccrual and/or impaired loans.
To the extent they are differen t, please provide the disclosures required by ASC 310 -10-
50-7(a) as provided by the example in ASC 310 -10-55-11 for nonaccrual loans. Please
also provide the disclosures required by paragraphs 15 -20 of ASC 310 -10-50 and as
provided by the example in ASC 31 0-10-55-10 for impaired loans.
 Disclose an age analysis of past due loans as required by ASC 310 -10-50-7A and as
provided in the example in ASC 310 -10-55-9.

We urge all persons who are responsible for the accuracy and adequacy of the disclosure
in the fil ing to be certain that the filing includes the information the Securities Exchange Act of
1934 and all applicable Exchange Act rules require.   Since the company and its management are
in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy
and adequacy of the disclosures they have made.

Lisa M. Young
Enova International, Inc.
August 26, 2014
Page 4

 In responding to our comments, please provide a written stateme nt from the company
acknowledging that:

 the company is responsible for the adequacy and accuracy of the disclosure in the filing;

 staff comments or changes to disclosure in response to staff comments do not foreclose
the Commission from taking any action with respect to the filing; and

 the company may not assert staff comments as a defense in any proceeding initiated by
the Commiss ion or any person under the federal securities laws of the United States.

You may contact John Spitz  at (202) 551 -3484  or Amit Pande  at (202) 551 -3423  if you
have questions regarding comments on the financial statements and related matters.  Please
conta ct Josh Samples  at (202) 551 -3199  or me at (202) 551 -3434 with any other questions.

Sincerely,

 /s/ Michael Clampitt

Michael Clampitt
Senior Staff Attorney

cc. Via E -mail
 Lindsay Ferguson
Hunton & Williams LLP

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SEC Response Letter

 HUNTON & WILLIAMS LLP

FOUNTAIN PLACE

 1445 ROSS AVENUE

SUITE 3700

 DALLAS, TEXAS 75202-2799

 TEL 214 • 979 • 3000

FAX 214 • 880 • 0011

 December 23, 2013

 Ms. Mara Ransom

Assistant Director

 United States Securities and
Exchange Commission

 101 F Street, NE

Washington, D.C. 20549

Re:
Cash America International, Inc.

Registration Statement on Form S-4

Filed November 12, 2013

File No. 333-192279 (the “Registration Statement”)

 Ladies and Gentlemen:

 On behalf of Cash America International, Inc. (the
“Company”), we are transmitting the following responses of the Company to the comments of the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”), as set forth in the letter of Ms. Mara
Ransom, Assistant Director, dated December 12, 2013 (the “Comment Letter”), regarding the Registration Statement referenced above. The Company is filing on EDGAR these responses concurrently with the filing of Amendment No. 1 to
the Registration Statement (the “Amendment”). The Amendment incorporates changes responsive to the comments set forth in the Comment Letter. For your convenience, we have repeated each comment in italics prior to the response.

The references to page numbers in the headings are to the original Registration Statement, and all references to page numbers in the
Company’s responses below are to the Amendment. All references in this letter to “exchange offer” refer to the exchange offer being registered by the Registration Statement.

 General

1.
We note that you are registering the New Notes in reliance on our position enunciated in Exxon Capital Holdings Corp., SEC No-Action Letter (April 13, 1998). See
also Morgan Stanley & Co. Inc., SEC No-Action Letter (June 5, 1991) and Shearman & Sterling, SEC No-Action Letter (July 2, 1993). Accordingly, with the next amendment, please provide us with a supplemental letter stating that you
are registering the exchange offer in reliance on our position contained in these letters and include the representations contained in the Morgan Stanley and Shearman & Sterling no-action letters.

 United States Securities and Exchange Commission

Ms. Mara Ransom

 December 23, 2013

Page 2

Company Response:

The new notes are intended to be registered in reliance on the position that the Staff enunciated in Exxon Capital Holdings Corp., SEC No-Action Letter
(April 13, 1988) (the “Exxon Capital Letter”), Morgan Stanley & Co. Inc., SEC No-Action Letter (June 5, 1991) (the “Morgan Stanley Letter”), and Shearman & Sterling, SEC No-Action Letter (July 2,
1993) (the “Shearman & Sterling Letter,” and together with the Exxon Capital Letter and the Morgan Stanley Letter, the “Exxon Capital line of letters”). The Company has provided the Staff with a supplemental letter
attached as Appendix A to this letter. The supplemental letter states that the Company is registering the exchange offer in reliance on the Staff’s position contained in the Exxon Capital line of letters and includes the representations
contained in the Morgan Stanley Letter and the Shearman & Sterling Letter.

2.
As currently represented, the offer could be open for less than 20 full business days due to the 5:00 p.m. expiration time instead of an expiration time of midnight
on what ultimately may be the twentieth business day following commencement. See Question and Answer Eight in Exchange Act Release No. 16623 (March 5, 1980). Please confirm that the offer will be open at least through midnight on the twentieth
business day. See Rule 14d-1(g)(3).

Company Response:

The Company confirms that the exchange offer will be open at least through midnight on the twentieth business day to ensure compliance with Rule 14d-1(g)(3) of the
Securities Exchange Act of 1934, as amended.

 The Exchange Offer, page 51

Exchange of Old Notes for Notes or Return of Old Notes, page 56

3.
We note the disclosure indicating that you will issue the Notes “promptly after acceptance” of the old notes. Rule 14e-1(c) requires that you exchange the
notes or return the old notes “promptly” upon expiration or termination of the offer, as applicable. Please revise here and throughout the document, as necessary.

 United States Securities and Exchange Commission

Ms. Mara Ransom

 December 23, 2013

Page 3

Company Response:

The disclosure in the Amendment has been revised to provide that the Company will exchange the notes or return the old notes promptly upon expiration or termination of
the exchange offer.

 Modification or Termination of Exchange Offer, page 56

4.
We note that you may determine in your “sole judgment” whether certain offer conditions have occurred or are satisfied. Please revise to include an
objective standard for the determination of whether a condition has been satisfied.

Company Response:

The disclosure in the second bullet point in the “Modification or Termination of Exchange Offer” section on page 56 of the Amendment has been revised as
follows:

 any government or governmental authority, domestic or foreign, brings or threatens any
legal action or threatens to enact any law seeking to prohibit the exchange offer or assessing or seeking any damages as a result of the exchange offer, or resulting in a material delay in our ability to accept any of the old notes for exchange; or
if such legal action or law would result in the holders of Notes having obligations with respect to resales and transfers of Notes that are greater than those we described above in the interpretations of the staff of the SEC or would otherwise make
it inadvisable to proceed with the exchange offer; or

 Description of the Notes, page 59

Guarantors, page 60

5.
It appears that you have provided the narrative disclosure set forth in Note 1 to Rule 3-10(f) of Regulation S-X in exhibits 99.1 and 99.2 to the Form 8-K filed on
November 12, 2013. Please tell us whether each of your subsidiary guarantors is 100% owned by you, with a view to clarifying your eligibility to rely on Rule 3-10(f) of Regulation S-X. In this regard, we note that the definitions of
“Subsidiary” and “Domestic Subsidiary,” as set forth in the indenture dated May 15, 2013, appear to contemplate subsidiary entities that are not wholly owned by you.

 United States Securities and Exchange Commission

Ms. Mara Ransom

 December 23, 2013

Page 4

Company Response:

All of the subsidiary guarantors are 100% owned by the Company except RATI Holding, Inc. (“RATI”). The Company owns 90.1% of RATI, and RATI’s business
operations were discontinued in September 2001. RATI has no independent assets or liabilities and no revenue or operating activities for the years ended December 31, 2012, 2011 or 2010, or for the nine months ended September 30, 2013. The
assets and operations for all periods referenced in the Registration Statement related to RATI were zero, except for operations during 2010 that only included immaterial wind-down expenses. Since this is the case, and in order to simplify this
issue, the Company has dissolved RATI pursuant to a Certificate of Termination filed with the Texas Secretary of State on December 18, 2013. As a result, all of the remaining subsidiary guarantors are 100% owned by the Company. The Company
advises the Staff that such dissolution was permitted in accordance with Section 5.01(6)(ii) of the Indenture, which permits the dissolution of non-wholly-owned subsidiaries, subject to certain requirements which were satisfied. Based on these
facts, the Company respectfully submits that it is eligible to rely on Rule 3-10(f) of Regulation S-X.

6.
We note that your subsidiary guarantors may in some circumstances be released from their obligations to guarantee the Exchange Notes issued in your offering. In
order to rely on the exceptions contained in Rule 3-10 of Regulation S-X, subsidiary guarantors may only be released from their guarantees in customary circumstances. In light of the above, please provide us with your analysis as to how the
guarantees constitute “full and unconditional” guarantees, with a view to understanding how the guarantees satisfy the requirements of Rule 3-10 of Regulation S-X. In your analysis, please focus on Section 10.09(2) of the Indenture
filed as Exhibit 4.1 to the Form 8-K filed on May 15, 2013.

Company Response:

 The terms of the Company’s subsidiary guarantees are specified in Article 10 of the Indenture governing the notes. Each of the subsidiary
guarantees is intended to be “full and unconditional” for purposes of Rule 3-10(h)(2) of Regulation S-X. Rule 3-10(h)(2) requires that “when an issuer of a guaranteed security has failed to
make a scheduled payment, the guarantor is obligated to make the scheduled payment immediately and, if it doesn’t, any holder of the guaranteed security may immediately bring suit directly against the guarantor for payment of all amounts due
and payable.” This concept is further explained in the adopting release for Rule 3-10 of Regulation S-X, which makes clear that a guarantee can be full and unconditional even if it includes a savings clause related to bankruptcy or fraudulent
conveyance, and specifically states that the full and unconditional status would not be defeated if the guarantee provides that it is enforceable “to the fullest extent permitted by law.” In addition,

 United States Securities and Exchange Commission

Ms. Mara Ransom

 December 23, 2013

Page 5

Section 2510.5 (“Section 2510.5”) of the Financial Reporting Manual of the Division of Corporate Finance notes that registrants may rely on Rule 3-10 of Regulation S-X when the
guarantee may be automatically released under customary circumstances. Section 2510.5 identified six guarantee release provisions that are considered customary circumstances, although the list is not exhaustive.

The subsidiary guarantee release provisions are contained in Section 10.09 of the Indenture. The Company respectfully submits that the subsidiary guarantee release
provisions contained in the Indenture are customary in accordance with the Staff’s guidance set forth in Section 2510.5 and the Company believes that it is therefore entitled to avail itself of the relief provided by Section 2510.5. A
detailed discussion of each release provision in relation to the Staff’s guidance is as follows:

Section 10.09(1): Section 10.09(1) of the Indenture provides for termination of a subsidiary guarantee upon “a sale or other disposition
(including by way of consolidation or merger) of the Guarantor or the sale or disposition of all or substantially all the assets of the Guarantor (in each case other than to the Company or a Guarantor) otherwise permitted by the Indenture.”
Section 2510.5 recognizes that a customary release provision is that if “the subsidiary is sold or sells all of its assets,” and that is the circumstance contemplated by Section 10.09(1) of the Indenture. The Company respectfully
submits that the parenthetical phrases “including by way of consolidation or merger” and “in each case other than to the Company or a Guarantor” do not cause this release provision to be non-customary and understands that the
Staff has accepted similar indenture language in Atlas Pipeline Partners, L.P. correspondence (available September 3, 2013), DriveTime Automotive Group, Inc. correspondence (available July 30, 2013), and CDW Corporation correspondence
(available January 21, 2012).

Section 10.09(2): Section 10.09(2) of the Indenture (“Section 10.09(2)”) provides for termination of a subsidiary guarantee upon, “if
the Note Guaranty was required pursuant to the terms of the Indenture, the cessation of the circumstances requiring the Note Guaranty (such termination to include, for the avoidance of doubt, the case of any discharge and release of a Guarantor from
its guarantee of Indebtedness under each Principal Credit Facility, provided that such Guarantor is not a borrower under or otherwise obligated under any Principal Credit Facility after giving effect to such discharge and release and
provided, further that, if, in connection with any such release of a Guarantor, any lender or agent under a Principal Credit Facility is paid any remuneration as consideration for such release, then such remuneration shall be
concurrently paid, on the same terms, ratably to each Holder in connection with the termination of the Note Guaranty of such Guarantor).” Section 2510.5 recognizes that a customary release provision is that the “subsidiary’s
guarantee of other indebtedness is terminated or released,” and that is the circumstance contemplated by Section 10.09(2), as more fully discussed below.

 United States Securities and Exchange Commission

Ms. Mara Ransom

 December 23, 2013

Page 6

Section 10.09(3): Section 10.09(3) of the Indenture provides for the termination of a subsidiary guarantee upon the “defeasance or discharge of
the Notes, as provided in “Defeasance and Discharge.”” Section 2510.05 recognizes a customary release provision is “the requirements for legal defeasance or covenant defeasance or to discharge the indenture have been
satisfied” and that is the circumstance contemplated by Section 10.09(3) of the Indenture.

In response to the Staff’s comments to specifically focus on the subsidiary guarantee release provisions contained in Section 10.09(2), the Company
respectfully submits that the release of a subsidiary guarantor pursuant to Section 10.09(2) is consistent with the third bullet point example in Section 2510.5, and thus is a customary circumstance under which a guarantee may be released.
In that regard, the Company notes that the release provision contained in Section 10.09(2) contains the following: “if, in connection with any such release of a Guarantor, any lender or agent under a Principal Credit Facility is paid any
remuneration as consideration for such release, then such remuneration shall be concurrently paid, on the same terms, ratably to each Holder in connection with the termination of the Note Guaranty of such Guarantor.” This means that if, in
connection with such release of a subsidiary guarantor under a Principal Credit Facility, there is remuneration paid to the lender or agent under the Principal Credit Facility, the subsidiary guarantee is permitted to be released only if each holder
of the notes is also paid, ratably, such remuneration so that the note holders are treated the same as the lenders under the Principal Credit Facilities. Consequently, this clause acts for the benefit of the noteholders as a further limitation upon
release of the guarantees upon termination of a subsidiary guarantor’s obligations under the Company’s Principal Credit Facilities rather than as an independent basis upon which a release may be obtained. Consequently, as a more limited
right, the Company respectfully submits that Section 10.09(2) falls well within what would be customary circumstances for a guarantee release.

 We understand that the Staff has accepted indenture language as coming within the “sale” example in the first bullet point of
Section 2510.5 where the release of the subsidiary guarantee upon a sale of the guarantor was permitted under the indenture only if the proceeds of the sale were applied in accordance with the terms of the indenture to pay down secured debt and
senior debt and for other purposes, including the application of any sales proceeds in excess of $25 million to repurchase notes issued under the indenture and repay other pari passu indebtedness, thus conditioning the “sale”
example in the first bullet point of Section 2510.5 upon this further limitation upon the release of the guarantor. See Atlas Pipeline Partners, L.P. correspondence (available September 3, 2013). The Company respectfully submits that the
limitation upon the release of the Company’s subsidiary guarantees discussed in the preceding paragraph is analogous to the more limited right in the Atlas Pipeline Partners

 United States Securities and Exchan

December 12, 2013

Via E -mail
Daniel R. Feehan
Chief Executive Officer
Cash America International, Inc.
1600 West 7th Street
Fort Worth, Texas 76102

Re: Cash America International, Inc.
  Registration Statement on Form S-4
Filed  November 12, 2013
  File No.  333-192279

Dear Mr. Feehan :

We have limited our review of your registration statement to those issues we have
addressed in our comments.  In  some of our comments, we may ask you to provide us with
information so we may better understand your disclosure.

Please respond to this letter by amending your registration statement and providing the
requested information .  Where you do not believe our comments apply to your facts and
circumstances or do not believe an amendment is appropriate, please tell us why in your
response.

After reviewing any amendment to your registration statement and the information you
provide in response to these  comments , we may have  additional comments.

General

1. We note that you are registering the New Notes in reliance on our position enunciated in
Exxon Capital Holdings Corp., SEC No -Action Letter (April 13, 1998).  See also Morgan
Stanley & Co. Inc., SEC No -Action Letter (June 5, 1991) and Shearman & Sterling, SEC
No-Action Letter (July 2, 1993).  Accordingly, with the next amendment, please provide
us with a supplemental letter stating that you are registering the exchange offer in
reliance on our position containe d in these letters and include the representations
contained in the Morgan Stanley and Shearman & Sterling no -action letters.

2. As currently represented, the offer could be open for less than 20 full business days due
to the 5:00 p.m. expiration time instea d of an expiration time of midnight on what
ultimately may be the twentieth business day following commencement.  See Question
and Answer Eight in Exchange Act Release No. 16623 (March 5, 1980).  Please confirm

Daniel R. Feehan
Cash America International, Inc.
December 12, 2013
Page 2

 that the offer will be open at least through midnight on the twentieth business day.   See
Rule 14d -1(g)(3).

The Exchange Offer, page 51

Exchange of Old Notes for Notes or Return of Old Notes, page 56

3. We note the disclosure indicating that you will issue the Notes “promptly after
acceptance” of the  old notes.  Rule 14e -1(c) requires that you exchange the notes or
return the old notes “promptly” upon expiration or termination of the offer, as applicable.
Please revise here and throughout the document, as necessary.

Modification or Termination of Ex change Offer, page 56

4. We note that you may determine in your “sole judgment” whether certain offer
conditions have occurred or are satisfied.  Please revise to include an objective standard
for the determination of whether a condition has been satisfied.

Description of the Notes, page 59

Guarantors, page 60

5. It appears that you have provided the narrative disclosure set forth in Note 1 to Rule 3 -
10(f) of Regulation S -X in exhibits 99.1 and 99.2 to the Form 8 -K filed on November 12,
2013.  Please tell us whether each of your subsidiary guarantors is 100% owned by you,
with a view to clarifying your eligibility to rely on Rule 3 -10(f) of Regulation S -X.  In
this regard, we note that the definitions of “Subsidiary” and “Domestic Subsidiary,” as
set forth in the indenture dated May 15, 2013, appear to contemplate s ubsidiary entities
that are not wholly owned by you.

6. We note that your subsidiary guarantors may in some circumstances be released from
their obligations to guarantee the Exchange Notes issued in your offering.  In order to
rely on the exceptions contai ned in Rule 3 -10 of Regulation S -X, subsidiary guarantors
may only be released from their guarantees in customary circumstances.  In light of the
above, please provide us with your analysis as to how the guarantees constitute “full and
unconditional” guara ntees, with a view to understanding how the guarantees satisfy the
requirements of Rule 3 -10 of Regulation S -X.  In your analysis, please focus on Section
10.09(2) of the Indenture filed as Exhibit 4.1 to the Form 8 -K filed on May 15, 2013.

Daniel R. Feehan
Cash America International, Inc.
December 12, 2013
Page 3

 Exhibit 5.1.  Opinion of Hunton & Williams LLP

Page 3

7. We note that in the first paragraph of this page, counsel qualifies its opinion by
referencing Senior Transeastern Lenders v. Official Comm. of Unsecured Creditors,
stating that “the validity and enforcement of the  Guarantors’ obligations under the
Guarantees may be subject to the holding in that case.”  Please provide us with an
analysis as to why counsel believes that this qualification is necessary and appropriate
and why counsel does not believe that the qualifi cation detracts from counsel’s binding
obligation opinion.  Please refer to Section II.B.3.a of Staff Legal Bulletin No. 19,
available on our website.

8. Investors should not be required to look beyond the disclosure in the prospectus  or the
documents filed with or incorporated by reference to the prospectus to gain essential
information.  To the extent that counsel continues to believe that the above qualification
is appropriate, please ask counsel to include in the opinion a description of the case
referenc ed in counsel’s opinion and the possible impact of the holding in that case on
counsel’s binding obligation opinion, or include such disclosure in the prospectus, and
include in the legal opinion a cross -reference to such discussion.  We may have further
comment after reviewing your response.

We urge all persons who are responsible for the accuracy and adequacy of the disclosure
in the filing to be certain that the filing includes the information the Securities Act of 193 3 and
all applicable Securities  Act rules require.   Since the company and its management are in
possession of all facts relating to a company’s disclosure, they are responsible for the accuracy
and adequacy of the disclosures they have made.

Notwithstanding our comments, in the event you request acceleration of the effective date
of the pending registration statement please provide a written statement from the company
acknowledging that:

 should the Commission or the staff, acting pursuant to delegated authority, declare the
filing eff ective, it does not foreclose the Commission from taking any action with respect
to the filing;

 the action of the Commission or the staff, acting pursuant to delegated authority, in
declaring the filing effective, does not relieve the company from its fu ll responsibility for
the adequacy and accuracy of the disclosure in the filing; and

 the company may not assert staff comments and the declaration of effectiveness as a
defense in any proceeding initiated by the Commission or any person under the federal
securities laws of the United States.

Daniel R. Feehan
Cash America International, Inc.
December 12, 2013
Page 4

 Please refer to Rules 460 and 461 regarding requests for  acceleration .  We will consider a
written request for acceleration of the effective date of the registration statement as confirmation
of the fact that those r equesting acceleration are aware of their respective responsibilities under
the Securities Act of 1933 and the Securities Exchange Act of 1934 as they relate to the proposed
public offering of the securities specified in the above registration statement.  Please allow
adequate time  for us to review any amendment prior to the requested effective date of the
registration statement.

Please contact Dean Brazier, Staff Attorney , at (202) 551 -3485, Lisa Kohl, Staff
Attorney, at (202) 551 -3252,  or me at (202) 551 -3720  with any other questions.

Sincerely,

 /s/ Lisa M. Kohl for

Mara Ransom
Assistant Director

cc: L. Steven Leshin