RITE AID CORPORATION
30 Hunter Lane
Camp Hill, PA 17011
March 8, 2006
SENT VIA EDGAR AND FACSIMILE (202) 772-9217
Mr. Mark Brunhofer
Division of Corporation Finance
United States Securities and Exchange Commission
100 F Street N.E.
Washington, DC 20549
Re: | Rite Aid Corporation |
| Form 10-K for Fiscal Year Ended February 26, 2005 |
| File No. 1-058742 |
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| SEC Comment Letter dated February 7, 2006 |
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| Rite Aid Corporation |
| Response letter filed February 21, 2006 |
Dear Mr. Bruhnhofer:
We are responding to your additional questions we discussed in our telephone conversation on March 7, 2006.
A/R Securitization – SFAS 140 paragraph 10 (a) - servicing assets and liabilities
As outlined in the transaction documents, the company has agreed to take on servicing responsibilities for the commercial paper conduit. We believe that there is no asset or liability to record since the benefits of servicing are just adequate to compensate us as servicer for our servicing responsibilities.
Missing Acknowledgement
We acknowledge that:
• the company is responsible for the adequacy and accuracy of the disclosure in the filing;
• 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,
• 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.
If you have additional questions, please call me directly at (717) 731-6540.
/s/ Kevin Twomey |
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Kevin Twomey | |
Executive Vice President and Chief Financial Officer | |
