Company Name: Cash America International, Inc.
Public Availability Date: June 4, 2007

Document Sections:

INQUIRY LETTER
APPENDIX
STAFF REPLY LETTER

[INQUIRY LETTER]

March 29, 2007

Martin P. Dunn
Deputy Director
Division of Corporation Finance
Securities & Exchange Commission
100 F Street, NE
Washington, D.C. 20549

Re: Shareholder Proposal Submitted to Cash America International

Via FAX 202-772-9349

Dear Mr. Dunn:

On March 14, 2007, I wrote to you on behalf of Christian Brothers Investment Services, Inc. (the "Proponent"), which has submitted a shareholder proposal to Cash America International, inc. ("Cash America" or the "Company") for consideration at its year 2007 meeting of shareholders, in which letter I requested reconsideration of the Staff's grant of a no-action letter, dated March 5, 2007, to the Company on the ground that the Proponent's proposal related to the Company's "ordinary business operations (i.e. credit policies, loan underwriting and customer relations)".

In further support of our contention that shareholder proposals concerning Predatory Lending raise important matters of policy for the Company, and therefore are not excludable by virtue of Rule 14a-8(i)(7), we draw your attention to the fact that yesterday, March 28, 2007, the United States House Ways and Means Committee passed HR 1677, Section 7 of which is aimed at short term refund anticipation predatory loans, which loans are not unlike the short term predatory loans made by the Company. HR 1677 was introduced on March 26, 2007, and Section 7 is set forth as Appendix A to this letter.

In this connection, we note that the March 28, 2007, edition of The Wall Street Journal said that Internal Revenue Commissioner Mark Everson had

attacked "predatory" refund loans, which are short-term loans made by private-sector businesses at exceptionally high interest rates, typically to poor people.

We reiterate our requests that the Staff reconsider its grant of a no-action letter to the Company and deny the Company's request. In the event that upon reconsideration of the Staff decision the Staff adheres to that earlier decision, please request the Commission to review the Staff determination.

We would appreciate your telephoning the undersigned at 941-349-6164 with respect to any questions in connection with this matter or if the staff wishes any further information. Faxes can be received thru at the same number.

Sincerely yours,

/s/

Paul M. Neuhauser

cc: Paul W. Talbot
John Wilson
Dan Rosan
Fr. Mike Hoolahan

[APPENDIX]

EXHIBIT A

SEC. 7. PROHIBITION ON IRS DEBT INDICATORS FOR PREDATORY REFUND ANTICIPATION LOANS.

(a) In General. Subsection (f) of section 6011 (relating to promotion of electronic filing) is amended by adding at the end the following new paragraph:

"(3) Prohibition on irs debt indicators for predatory refund anticipation loans.

"(A) In general. In carrying out any program under this subsection, the Secretary shall not provide a debt indicator to any person with respect to any refund anticipation loan if the Secretary determines that the business practices of such person involve refund anticipations loans and related charges and fees that are predatory.

"(B) Refund anticipation loan. For purposes of this paragraph, the term `refund anticipation loan' means a loan of money or of any other thing of value to a taxpayer secured by the taxpayer's anticipated receipt of a Federal tax refund.

"(C) IRS debt indicator. For purposes of this paragraph, the term `debt indicator' means a notification provided through a tax return's acknowledgment file that a refund will be offset to repay debts for delinquent Federal or State taxes, student loans, child support, or other Federal agency debt.".

[STAFF REPLY LETTER]

June 4, 2007

Paul M. Neuhauser
Attorney at Law
5770 Midnight Pass Road
Sarasota, FL 34242

Re: Cash America International, Inc. Incoming letter dated March 29, 2007

Dear Mr. Neuhauser:

This is in response to your letter dated March 29, 2007, which we received on April 26, 2007, concerning a shareholder proposal submitted to Cash America by Christian Brothers Investment Services, Inc. On March 5, 2007, we issued our response expressing our informal view that we would not recommend enforcement action to the Commission if Cash America omitted the proposal from its proxy materials in reliance on rule 14a-8(i)(7). On March 26, 2007, we issued our response indicating that after reviewing the information contained in your March 14, 2007 letter, we found no basis to reconsider our position and determined not to present your request to the Commission. After reviewing the information contained in your March 29, 2007 letter, we find no basis to reconsider our position.

Sincerely,

/s/

Martin P. Dunn
Deputy Director

cc: Paul M. Talbot
Associate General Counsel
Cash America International, Inc.
1600 West 7\th/ Street
Fort Worth, TX 76102