May 9, 2014
Via EDGAR
Mr. John Cash
Accounting Branch Chief
U.S. Securities and Exchange Commission
Division of Corporation Finance
100 F. Street, NE
Washington, D.C. 20549
Re: Rent-A-Center, Inc.
Form 10-K for the Fiscal Year Ended December 31, 2013 (the Form 10-K)
Filed March 3, 2014
File No. 0-25370
Dear Mr. Cash:
This letter sets forth the responses of Rent-A-Center, Inc. (the Company) to the comment of the staff of the Division of Corporation Finance (the Staff) of the Securities and Exchange Commission (the Commission) received by letter dated May 6, 2014 (the Comment Letter) with respect to the above-referenced filing. For the convenience of the Staff, we have set forth below, in boldface type, the text of the comment in the Comment Letter followed by the Companys response thereto.
Form 10-K for the Fiscal Year Ended December 31, 2013
Item 7. Managements Discussion and Analysis of Financial Condition and Results of Operations, page 20
Comparison of the Years Ended December 31, 2013 and 2012
1. In future annual and quarterly filings, please provide a discussion of the comparison of the consolidated results between periods that you previously provided, as found on pages 28-29 of your Form 10-K, in addition to your discussion of segment performance. We believe that your previously disclosed narrative provides investors with detailed and quantified information regarding the reasons for significant changes in the line items on your statement of earnings.
Response: In future annual and quarterly filings, we will provide a discussion of the comparison of the consolidated results between periods such as that found on pages 28-29 of our Form 10-K, in addition to our discussion of segment performance.
In addition, pursuant to your request, the Company acknowledges that: (i) the Company is responsible for the adequacy and accuracy of the disclosure in the Companys filings with the Commission; (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 Company 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.
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Should any member of the Staff have any questions or additional comments regarding the Companys responses to the Staffs comments set forth above, please do not hesitate to contact Dawn Wolverton in the Companys legal department at (972) 801-1160, or by facsimile at (972) 801-1476.
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Sincerely, |
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/s/ Michael S. Wilding |
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Michael S. Wilding |
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Senior Vice PresidentAccounting, Global Controller and Interim Chief Financial Officer |
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Rent-A-Center, Inc. |
cc: Dale Welcome, Securities and Exchange Commission
Dawn M. Wolverton, Rent-A-Center, Inc.
Thomas W. Hughes, Norton Rose Fulbright (Fulbright & Jaworski L.L.P.)
Stacy Sturgeon, KPMG LLP