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March 30, 2012   Mr. Jason Berg Principal Financial Officer AMERCO 1325 Airmotive Way, Suite 100 Reno, Nevada 89502-3239
Re: AMERCO
 Form 10-K for the Fiscal Year Ended March 31, 2011
Filed June 9, 2011 Definitive Proxy Statement on Schedule 14A Filed July 15, 2011 Form 10-Q for the Quarterly Period Ended December 31, 2011
Filed February 8, 2012 File No. 001-11255

Dear Mr. Berg:
 We have reviewed your filing and have the following comments.  In some of our
comments, we may ask you to provide us with  information so we may better understand your
disclosure.
 Please respond to this letter within ten business days by amending your filing, by
providing the requested information, or by advi sing us when you will provide the requested
response.  If you do not believe our comments apply to your fact s and circumstances or do not
believe an amendment is appropriate, pl ease tell us why in your response.
 After reviewing any amendment to your filing and the information you provide in
response to these comments, we ma y have additional comments.
            Form 10-K for the Fiscal Year Ended March 31, 2011

 General

1. We note your effective registration statem ent on Form S-3 (File No. 333-169832).  We
also note that you have filed a number of pros pectus supplements pursuant to Rule 424 of
the Securities Act of 1933 and a number of cu rrent reports on Form 8-K related to the
offering of securities pursuant to such regist ration statement.  We further note that the
current reports on Form 8-K included unqualified opinions of counsel with respect to the
legality of the securities being offered.  La stly, we note that in a number of cases it is

Mr. Jason Berg AMERCO March 30, 2012 Page 2

 unclear whether the unqualified opinions of counsel were fi led prior to closing of the
offering.  For example, refer to the prospectus supplement filed on November 8, 2011 and the associated current report on Form 8-K filed on January 18, 2012.  Please confirm
that in any subsequent offerings of securi ties pursuant to the aforementioned registration
statement you will file an unqualif ied opinion of counsel no later than the closing date of
the offering of securities covere d by the registration statement.

2. We note that the unqualified opinions of c ounsel filed in connection with the above
referenced registration statement are limited to the laws of New York.  We also note that
the company is a Nevada corporation.  Please co nfirm that in any subsequent offerings of
securities pursuant to the above referen ced registration statement that you will have
counsel opine upon the laws of New York a nd Nevada or, alternatively, you will file
unqualified opinions of local Nevada counsel in which counsel opines that the company
is validly existing, has the power to create the obligations, and has taken the required
steps to authorize entering in to the obligations.  Refer to Section II.B.1.e. of Staff Legal
Bulletin No. 19 for further guidance.
 Management’s Discussion and Analysis

 Fiscal 2011 Compared w ith Fiscal 2010, page 23

3. Refer to your discussions of self-moving e quipment rental revenues and self-storage
revenues in the first two paragraphs of th is section.  In each case, you attribute the
increase in revenues to two fact ors.  Where variances in line items are the result of more
than one factor and/or of offsetting factors,  the impact of each of  the factors should be
quantified if practicable.  Our comment a ddresses comparative discussions throughout
your narrative, as applicable.
 Financial Statements

 Consolidated Statements of Cash Flows, page F-6

4. We note the securitization deposits of approximately $46.8 million included under
financing activities in fiscal 2011.  Please ex plain the nature of and reasons for these
deposits and tell us how the required amount s are determined.  Address the activity in
these deposits through September 30, 2011 as well in your response.
 Definitive Proxy Statement on Schedule 14A

5. Please refer to item number 2 on your proxy card for your 2011 annual meeting of
stockholders.  In future filings, please conf irm that you will include an advisory vote
description that is consiste nt with the Exchange Act Rule 14a-21 requirement for
shareholders to be given an advisory vot e to approve the compensation paid to a
company’s named executive officers, as disc losed pursuant to Item 402 of Regulation S-
K.  For further guidance, please refer to Ex change Act Rules Compliance and Disclosure
Interpretation 169.07.

Mr. Jason Berg AMERCO March 30, 2012 Page 3

 Form 10-Q for the Quarter Ended December 31, 2011

 Management’s Discussion and Analysis

Critical Accounting Policies and Estimates, page 39
6. Refer to your discussion of insurance rese rves on pages 41 and 42.  We note that
insurance reserve adequacy is reviewed by ma nagement on a regular basis to determine if
existing assumptions need to be dated.  We also note that Repwest conducted a “more in-
depth review” of its claims during the fourth quarter of the calendar year (the basis upon
which it reports as required by state insurance departments).  This in-depth review was
conducted because new information regarding re cent loss trends emerged.  To facilitate
our understanding of these events  and circumstances please describe, supplementally and
in detail, your routine an nual processes for monitoring and managing these claims.
Describe, in expanded detail, the new info rmation that emerged regarding recent loss
trends, tell us how it emerged and indicate the period over which this new information
became known to the company.  Specify the period over which your in-depth review was conducted and describe in detail how this review differed from your regular review
process.  Finally, please explain how you have  bolstered your routine review process “to
encourage a proactive assessmen t of the claims going forward and adjust projected claim
costs in a timely manner.”  We may ha ve further comments upon review of your
response.

7. As a related matter, we note that A.M. Best  downgraded your financia l strength rating to
B and your issuer credit rating to bb+ in February 2012 and that each of these ratings
were placed under review with negative imp lications.  Supplementally and in detail,
describe how each of these events may reasonably be expected to impact the property and casualty insurance operating segment and AMERCO as a whole.

We urge all persons who are responsible for th e accuracy and adequacy of the disclosure
in the filing to be certain that the filing include s the information the Securities Exchange Act of
1934 and all applicable Exchange Act rules requir e.  Since the company and its management are
in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy
and adequacy of the disclosures they have made.
 In responding to our comments, please provi de a written statement from the company
acknowledging that:
 the company is responsible for the adequacy an d accuracy of the disclo sure 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 federa l securities laws of  the United States.

Mr. Jason Berg AMERCO March 30, 2012 Page 4

 You may contact Kristin Shi fflett at 202-551-3381 or Marg ery Reich at 202-551-3347 if
you have questions regarding comments on the fina ncial statements and related matters.  Please
contact Donald Field at 202-551-3680, Justin  Dobbie at 202-551-3469 or me at 202-551-3211
with any other questions.
Sincerely,
   /s/ David R. Humphrey
David R. Humphrey Accounting Branch Chief