SEC-generated letter Ezcorp Inc

UPLOAD [Cover] - SEC-generated letter

Published: 2018-04-03 15:57:11
Submitted: 2018-04-03
filename1.pdf


Mail Stop 3561

                                                               April 3, 2018

   Daniel M. Chism
   Chief Financial Officer
   EZCorp, Inc.
   2500 Bee Cave Road
   Building One, Suite 200
   Rollingwood, Texas 78746

           Re:    EZCorp, Inc.
                  Form 10-K for the Fiscal Year Ended September 30, 2017
                  Filed November 15, 2017
                  Form 10-Q for the Quarterly Period Ended December 31, 2017
                  Filed January 31, 2018
                  File No. 0-19424

   Dear Mr. Chism:

           We have limited our review of your filings 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 for the Fiscal Year Ended September 30, 2017

   Item 8 – Financial Statements and Supplementary Data

   Note 1: Summary of Significant Accounting Policies

   Notes Receivable, page 59

       1. We note your disclosures here and in Note 5 that you restructured the repayment
          arrangements for certain notes receivable from Grupo Finmart referred to as the Parent
          Loan Notes. It appears that you accounted for this restructuring as an extinguishment of
          the old notes and issuance of new notes. Please tell us the analysis you went through
          when considering whether this restructuring is a troubled debt restructuring. In doing so,


Daniel M. Chism
EZCorp, Inc.
April 3, 2018
Page 2


       tell us how you considered whether Grupo Finmart is experiencing financial difficulties
       and how you determined you did not grant Grupo Finmart a concession. Refer to ASC
       310-40-15.

Form 10-Q for the Quarterly Period Ended December 31, 2017

Item 1 Financial Statements

Notes to Interim Condensed Consolidated Financial Statements (Unaudited)

Note 2: Acquisitions, page 7

    2. Please provide all of the disclosures required by ASC 805-10-50 for the acquisitions of
       GPMX and the Bazareno stores. In this regard, tell us and revise to disclose the amounts
       of revenue and earnings since the acquisition date included in the consolidated statement
       of operations for the reporting period as required by ASC 805-10-50-2(h).

    3. Please tell us how you determined it was impracticable to provide supplemental pro
       forma information for your GPMX acquisition. In doing so, describe to us in more detail
       the limitations encountered by management. Since you disclose that there is a lack of
       readily available historical GAAP basis financial statements, tell us the accounting
       framework under which GPMX prepared its historical pre-acquisition financial
       statements and tell us whether you plan to obtain pre-acquisition financial statements
       prepared in accordance with US GAAP. Refer to ASC 805-10-50-2(h) and ASC 250-10-
       45-9.

    4. Please tell us how you determined that it was not necessary to provide audited financial
       statements of GPMX in accordance with Rule 3-05 of Regulation S-X. In doing so,
       provide us with your significance calculations pursuant to Rules 3-05(b)(2) and 1-02(w)
       of Regulation S-X. Also, please tell us whether significance was determined using US
       GAAP amounts for the acquired GPMX business.

        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.


Daniel M. Chism
EZCorp, Inc.
April 3, 2018
Page 3


      You may contact Robert Babula, Staff Accountant at (202) 551-3339, or me at (202) 551-
3737 with any questions.

                                                        Sincerely,

                                                        /s/ Jennifer Thompson

                                                        Jennifer Thompson
                                                        Accounting Branch Chief
                                                        Office of Consumer Products



Document Created: 2018-04-03 15:56:20
Document Modified: 2018-04-03 15:56:20
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