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United States securities and exchange commission logo
September 21, 2022
Maureen Short
Executive Vice President and CFO
Rent-A-Center, Inc.
5501 Headquarters Drive
Plano, Texas 75024
Re: Rent-A-Center, Inc.
Form 10-K for the
Fiscal Year Ended December 31, 2021
Filed February 28,
2022
Form 10-Q for the
Fiscal Quarter Ended June 30, 2022
Filed August 5,
2022
File No. 001-38047
Dear Ms. Short:
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 December 31, 2021
Management's Discussion and Analysis of Financial Condition and Results
of Operations
Results of Operations
Comparison of the Years Ended December 31, 2021 and 2020
Gross Profit, page 39
1. Please discuss in
detail here how Acima's use of a different merchandise lease
depreciation policy
results in a lower consolidated gross margin relative to the
depreciation policy for
other operations so investors may have a better understanding of
its continuing effect.
Refer to Item 303(b)(2)(i) of Regulation S-K. Also consider similar
disclosure in your
discussion of segment operating profit for the Acima segment to the
extent meaningful going
forward.
Maureen Short
Rent-A-Center, Inc.
September 21, 2022
Page 2
Revenues, page 40
2. Please explain what "higher portfolio balance" represents and how it
affects the amount of
revenues reported.
Segment Performance
Rent A Center Business Segment, page 40
3. Please quantify in your annual and interim period filings the factors
cited for changes in
consolidated and segment results. Refer to section 501.04 of the staff
s Codification of
Financial Reporting Policies. Consider the preceding in your analysis
of operating cash
flow on page 41. Also refer to Item 303(b)(2)(iii) of Regulation S-K
regarding the change
in revenues. Additionally, discuss if the growth in e-commerce
revenues is a known
favorable/unfavorable trend that is expected to materially affect
segment and consolidated
results. Refer to Item 303(b)(2)(ii) of Regulation S-K.
Form 10-Q for the Fiscal Quarter Ended June 30, 2022
Financial Statements
Notes to Condensed Consolidated Financial Statements
Note 4 - Receivables and Allowance for Doubtful Accounts, page 11
4. We note in your earnings calls for the periods ended December 31,
2021, March 31, 2022
and June 30, 2022 that you tightened and enhanced your underwriting
guidelines that
affected provisions for delinquencies and credit losses in the Acima
business segment.
However, it appears your accounting policy regarding receivables and
allowance for
doubtful accounts has not changed from that disclosed at December 31,
2020. Please
explain to us your consideration of ASC 326-20-50-10 and 11 regarding
the impact of the
Acima acquisition on your policy.
Management's Discussion and Analysis of Financial Condition and Results of
Operations
Business and Operational Trends
Other Macroeconomic Conditions and Changes in underwriting, page 26
5. You disclose you have been impacted by negative macroeconomic trends,
including a
condensed labor market, wage inflation, global supply chain issues and
inflation affecting
your revenues and underwriting. Please expand your disclosure to
identify the principal
factors contributing to these issues and clarify the resulting impact on
you. Additionally,
disclose any known trends or uncertainties regarding these issues that
are reasonably
FirstName LastNameMaureen Short
likely to have a material impact on your cash flows, liquidity, capital
resources, cash
Comapany NameRent-A-Center,
requirements, Inc. or results of operations. Refer to Item
303(b)(2)(ii) of
financial position,
Regulation
September S-K.
21, 2022 Page 2
FirstName LastName
Maureen Short
FirstName LastNameMaureen Short
Rent-A-Center, Inc.
Comapany 21,
September NameRent-A-Center,
2022 Inc.
September
Page 3 21, 2022 Page 3
FirstName LastName
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 Robert Shapiro at 202-551-3273 or Doug Jones at
202-551-3309 with
any questions.
Sincerely,
Division of
Corporation Finance
Office of Trade &
Services