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September 29, 2023
Edward J. Shoen
President and Chairman of the Board
U-Haul Holding Company
5555 Kietzke Lane, Suite 100
Reno, Nevada 89511
Re:U-Haul Holding Company
Definitive Proxy Statement on Schedule 14A
Filed July 7, 2023
File No. 001-11255
Dear Edward J. Shoen:
            We have limited our review of your most recent definitive proxy statement to those issues
we have addressed in our comments.  Please respond to these comments by confirming that you
will revise your future proxy disclosures in accordance with the topics discussed below.
Definitive Proxy Statement on Schedule 14A filed July 7, 2023
Pay versus Performance, page 11
1.Please identify each named executive officer included in the calculation of average non-
PEO named executive officer compensation, and the fiscal years in which such persons
are included.  You may provide this information in a footnote to the pay versus
performance table.  See Regulation S-K Item 402(v)(3).
2.Refer to the reconciliation table in footnote (3) to your pay versus performance table. It is
unclear what amounts are reflected in the row titled "Change in Value of Prior Equity
Awards."  Specifically, there are two separate subsections of Item 402(v)(2)(iii)(C)(1) that
require change in fair value calculations, each with different measurement end dates, and
these amounts must be separately disclosed.  Please ensure that your disclosure shows
each of the numerical amounts deducted and added to calculate compensation actually
paid, as required by Regulation S-K Item 402(v)(3), and to make clear the dates from and
to which changes in fair value are measured.  For guidance, refer to Regulation S-K
Compliance and Disclosure Interpretations Questions 128D.03 and 128D.04.
3.We note footnote (4) to your pay versus performance table states that the Dow Jones U.S.
Total Index is your peer group for purposes of your total shareholder return comparison.
This index appears to be a broad equity market index used for purposes of Regulation S-K
Item 201(e)(1)(i) and not the index or issuers used by you for purposes of Regulation S-K

 FirstName LastNameEdward J. Shoen
 Comapany NameU-Haul Holding Company
 September 29, 2023 Page 2
 FirstName LastName
Edward J. Shoen
U-Haul Holding Company
September 29, 2023
Page 2
Item 201(e)(1)(ii).  Please ensure that your peer group total shareholder return column and
related disclosure uses the same index or issuers used for purposes of Regulation S-K Item
201(e)(1)(ii) or the companies you use as a peer group for purposes of disclosure under
Regulation S-K Item 402(b).
4.We note that you identify “EBITDA” as your Company-Selected Measure in the pay
versus performance table; however, your remaining disclosure refers to “Moving and
Storage EBITDA.”  Please ensure that the disclosure required for your Company-Selected
Measure refers to the same measure throughout.  Please note that while you may
voluntarily provide supplemental measures of compensation or financial performance, any
such additional disclosure "must be clearly identified as supplemental, not misleading, and
not presented with greater prominence than the required disclosure." See Pay Versus
Performance, Release No. 34–95607 (Aug. 25, 2022) [87 FR 55134 (Sept. 8, 2022)] at
Section II.F.3.
            Please contact Alyssa Wall at 202-551-8106 or Amanda Ravitz at 202-551-3412 with any
questions.
Sincerely,
Division of Corporation Finance
Disclosure Review Program