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United States securities and exchange commission logo





                              February 13, 2024

       John Calmes, Jr.
       Chief Financial Officer
       World Acceptance Corporation
       104 S. Main St.
       Greenville, South Carolina 29601

                                                        Re: World Acceptance
Corporation
                                                            Form 10-K for
Fiscal Year Ended March 31, 2023
                                                            Form 10-Q for
Quarterly Period Ended December 31, 2023
                                                            File No. 000-19599

       Dear John Calmes, Jr.:

              We have limited our review of your filings to the financial
statements and related
       disclosures 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 March 31, 2023

       Risk Factor - Federal legislative or regulatory proposals, initiatives,
actions ..., page 20

   1.                                                   Please revise future
filings to quantify the amount of vehicle-secured loans originated
                                                        during the periods
presented in your filing with an annual percentage rate within the scope
                                                        of the CFPB final rule
under its unfair, deceptive and abusive acts and practices
                                                        rulemaking authority.
       Management's Discussion and Analysis of Financial Condition and Results
of Operations , page
       29

   2.                                                   Noting that Insurance
and other income, net comprised 18% of Total revenue, please
                                                        revise future filings
to include additional detail of the significant classes and types of
                                                        income presented in
this line item for each period presented and discuss material trends.
                                                        Please provide us your
proposed revised disclosure.
 John Calmes, Jr.
FirstName LastNameJohn Calmes, Jr.
World Acceptance Corporation
Comapany13,
February  NameWorld
            2024     Acceptance Corporation
February
Page 2 13, 2024 Page 2
FirstName LastName
Note (1) Summary of Significant Accounting Policies - Impaired Loans, page 49

3.       Please tell us and revise future filings to clarify the impact of a
loan being classified as
         impaired or revise to use more appropriate terminology consistent with
that used in ASC
         326.
4.       Please revise your charge-off policy in future filings to clarify the
criteria for when a loan
         is deemed uncollectible. In your December 31, 2023, Form 10-Q, we note
you disclose
         you charge-off loans when they reach 120 days past due on a recency
basis. Please
         provide us your proposed revised disclosure.
5.       Please tell us and revise future filings to clarify why you do not
charge-off bankrupt
         accounts and discuss when these accounts are considered uncollectible.
6.       Please revise future filings to quantify the rehab rate used for each
period presented and
         discuss in MD&A any material changes, the impact of the change on
financial results and
         the reasons for the change. Please provide us your proposed revised
disclosure.

Note (2) Allowance for Credit Losses and Credit Quality Information, page 54

7.       Considering your disclosure on pages 31, 32 and 61 there was a
significant increase in
         charge-offs in fiscal 2023 primarily due to loans to new borrowers
performing worse than
         expected due to macro-economic factors, please tell us and revise
future filings to clarify
         and bridge the gap with your disclosure on page 58 that due to the
short term nature of the
         loan portfolio, forecasted changes in macro-economic variables such as
unemployment do
         not have a significant impact on loans outstanding at the end of a
particular reporting
         period in estimating current expected credit losses.
8.       Please revise future filings to clearly describe if an adjustment has
been made at each
         period end for your reasonable and supportable forecast. To the extent
the adjustment has
         a material impact in any period presented, please revise to include a
discussion of the
         factors that influenced the adjustment. Refer to ASC 326-20-50-11 for
guidance. Please
         provide us your proposed revised disclosure.
9.       We note your disclosure related to your accounting policies for
non-filing insurance on
         page 51. Please tell us and revise future filings to more clearly
describe how non-filing
         insurance impacts your estimate of expected credit losses. For
example, clarify if you
         reduce your allowance for credit losses for estimated insurance claims
or if your estimate
         of expected credit losses is only reduced when claims are received.
Specifically disclose if
         claims paid as disclosed in Note 8 are recognized as recoveries.

Note (13) Asset Acquisitions, page 74

10.      We note your disclosure related to the $5.2 million gain recognized
from asset
         acquisitions. Please provide us with an accounting analysis which
explains how you
 John Calmes, Jr.
World Acceptance Corporation
February 13, 2024
Page 3
         accounted for these transactions. At a minimum, please include the
following information
         in your analysis:

             how you considered whether the transactions were in the scope of
ASC 835-30-25-4 or
         ASC 805-50; and
             how you determined the relevant accounting guidance supported
immediate recognition
         of a gain.


Form 10-Q for Quarterly Period Ended December 31, 2023

Note 4 - Loans Receivable and Allowance for Credit Losses, page 14

11.      We note you charge-off loans at the earlier of 120 days past due or
when deemed
         uncollectible. Please tell us the typical facts and circumstances when
a loan is deemed
         uncollectible and charged-off prior to being 120 days past due and
provide us an estimate
         of the magnitude of loans charged-off prior to 120 days past due. To
the extent material,
         please revise future filings to disclose 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.

       Please contact Michael Volley at 202-551-3437 or Amit Pande at
202-551-3423 with any
questions.



FirstName LastNameJohn Calmes, Jr.                            Sincerely,
Comapany NameWorld Acceptance Corporation
                                                              Division of
Corporation Finance
February 13, 2024 Page 3                                      Office of Finance
FirstName LastName
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