United States securities and exchange commission logo
March 16, 2021
Jeffrey Williams
Chief Executive Officer
America s Car-Mart, Inc.
1805 North 2nd Street, Suite 401
Rogers, Arkansas 72756
Re: America s
Car-Mart, Inc.
Form 10-K for the
Fiscal Year Ended April 30, 2020
Filed June 24, 2020
Form 10-Q for the
Quarterly Period Ended January 31, 2021
Filed March 5, 2021
File No. 0-14939
Dear Mr. Williams:
We have limited our review of your filings to the financial
statements and related
disclosures 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-Q for the Quarterly Period Ended January 31, 2021
Notes to Consolidated Financial Statements (Unaudited)
B Summary of Significant Accounting Policies
Finance Receivables, Repossessions and Charge-offs and Allowance for
Credit Losses, page 8
1. We note your disclosure
on page 12 that you adopted ASU 2016-13, Financial
Instruments Credit
Losses ( ASU 2016-13 ), on May 1, 2020 and that you did not incur
a material impact to
your financial statements as a result of the adoption. Please respond
to the following:
Describe the
reasons for the lack of any material change in your allowance for credit
losses upon the
adoption of ASU 2016-13 in light of the fact that the standard
eliminated the
probable initial recognition threshold under the prior GAAP model,
and instead
requires an entity s current estimate of all expected credit losses.
Jeffrey Williams
America s Car-Mart, Inc.
March 16, 2021
Page 2
We note several places in your disclosure where you refer to
losses inherent or
incurred in the portfolio, over the remaining contractual
lives. Please explain how
these references capture your estimate of all expected credit
losses over the
contractual lives of the loans, and not just losses that have
already been incurred.
We note your disclosure on page 13 that you use a 12 month
reasonable and
supportable forecast period, and then revert back to historical
loss information.
Please tell us and disclose in future filings how you revert back
to historical loss
information. Please refer to ASC 326-20-30-9 and 326-20-50-11g.
We note your disclosure on page 14 where you disclose the
finance receivables
outstanding at January 31, 2021 summarized by fiscal year of
origination. However,
we were unable to locate where you disclosed the credit quality
indicator for your
finance receivables by fiscal year of origination as required by
ASC 326-20-50-6 and
326-20-55-7. Please advise, or revise future filings to include
this information.
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 Ta Tanisha Meadows at (202) 551-3322 or Joel Parker at
(202) 551-
3651 with any questions.
FirstName LastNameJeffrey Williams Sincerely,
Comapany NameAmerica s Car-Mart, Inc.
Division of
Corporation Finance
March 16, 2021 Page 2 Office of Trade &
Services
FirstName LastName