United States securities and exchange commission logo
May 12, 2022
Timothy K. Jugmans
Chief Financial Officer
EZCORP, Inc.
2500 Bee Cave Road, Bldg One, Suite 200
Rollingwood, TX 78746
Re: EZCORP, Inc.
Form 10-K for
Fiscal Year Ended September 30, 2021
Filed November 17,
2021
File No. 000-19424
Dear Mr. Jugmans:
We have reviewed your filing and have the following comment. In
our comment, we
may ask you to provide us with information so we may better understand
your disclosure.
Please respond to this comment 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
comment applies to your facts and circumstances, please tell us why in
your response.
After reviewing your
response to this comment, we may have additional comments.
Form 10-K for Fiscal Year Ended September 30, 2021
Financial Statements
Consolidated Statements of Operations, page 40
1. You present two amounts
for revenues -- total revenues and net revenues. If total
revenues represent your
ASC 606 revenues, please relabel the profit measure you
currently call net
revenues to better reflect what it actually represents. Also, tell us
whether this profit
measure is fully burdened with all amounts that would be required to
be included in gross
profit. If it is not fully burdened, please tell us in detail how it is not.
In addition, please
present and discuss your ASC 606 revenues when you present and
discuss your results of
operations throughout your filings, such as on pages 4 and 5 of
your Business section
and in the Operating Results of your Management's Discussion and
Analysis section.
Timothy K. Jugmans
EZCORP, Inc.
May 12, 2022
Page 2
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 Angela Lumley at (202) 551-3398 or Rufus Decker at
(202) 551-3769,
if you have any questions.
FirstName LastNameTimothy K. Jugmans Sincerely,
Comapany NameEZCORP, Inc.
Division of
Corporation Finance
May 12, 2022 Page 2 Office of Trade &
Services
FirstName LastName