July 15, 2024
C. Kelly Wall
Chief Financial Officer
The Aaron's Company, Inc.
400 Galleria Parkway SE, Suite 300
Atlanta, Georgia 30339
Re: The Aaron's Company, Inc.
Form 10-K for Fiscal Year Ended December 31, 2023
Form 8-K Furnished May 6, 2024
File No. 001-39681
Dear C. Kelly Wall:
We have reviewed your filing and have the following comments.
Please respond to this letter 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 a
comment applies to your facts and circumstances, please tell us why in your
response.
After reviewing your response to this letter, we may have additional
comments.
Form 10-K for Fiscal Year Ended December 31, 2023
Management's Discussion and Analysis
Segment Performance - Years Ended December 31, 2023 and 2022, page 51
1. Where you attribute material fluctuations in your results to multiple
factors,
please quantify each factor cited so that investors may understand the
magnitude and
relative impact of each factor. As an example, you cite multiple factors
which caused a
decline in your lease revenues and fees and retail sales during the year
ended December
31, 2023 without quantification that would allow users to understand the
impact of each
material factor. Refer to Item 303(b) of Regulation S-K and Section
III.B of Release No.
33-8350.
July 15, 2024
Page 2
Notes to Consolidated Financial Statements
Note 7: Leases, page 88
2. We note your disclosure that all of the customer lease agreements are
considered
operating leases. Please tell us your consideration of the factors in
ASC 842-10-25-2 in
coming to this determination. Also consider expanding your summary of
significant
accounting policies to include factors considered.
Form 8-K Furnished May 6, 2024
Exhibit 99.1, page 1
3. When presenting and discussing your non-GAAP measure of Adjusted EBITDA
and your
non-GAAP consolidated outlook measures, please present and discuss the
comparable
GAAP measure(s) with equal or greater prominence. Refer to Item
10(e)(1)(i)(A) of
Regulation S-K and Question 102.10 of the staff's Compliance and
Disclosure
Interpretations on Non-GAAP Financial Measures.
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 Abe Friedman at 202-551-8298 or Theresa Brillant at
202-551-3307 if you
have questions regarding comments on the financial statements and related
matters.
Sincerely,
Division of
Corporation Finance
Office of Trade &
Services