SEC Company Response from U-Haul Holding (UHAL) — Mar 4, 2009
U-Haul Holding Co /NV/ (UHAL, UHAL-B) (CIK 0000004457)
Date: March 4, 2009 · CIK: 0000004457 · Accession: 0000004457-09-000004
AI Filing Summary & Sentiment
File numbers found in text: 001-11255
Referenced dates: January 29, 2009
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CORRESP
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filename1.htm
amercoresponse.htm
March 4,
2009
VIA
EDGAR
Mr.
Daniel Morris
Division
of Corporation Finance
Securities
and Exchange Commission
450 Fifth
Street, N.W.
Washington,
DC 20549
Re: AMERCO
Form 10-K for the Fiscal Year ended
March 31, 2008, Filed June 4, 2008
Schedule 14A filed July 15,
2008
Commission File Number
001-11255
Dear Mr.
Morris:
This
letter responds to the Staff’s comments contained in the letter dated January
29, 2009 and postmarked February 19, 2009 on the AMERCO, Inc. (the “Company”)
Form 10-K for the year ended March 31, 2008 and Schedule 14A filed July 15,
2008. We appreciate the opportunity to respond to your comments and
understand that the purpose of your review process is to assist the Company in
its compliance with the applicable disclosure requirements and to enhance the
overall disclosure in its filings.
Form 10-K for the Annual
Period Ended March 31, 2008
Risk Factors, page
7
Starting
with our Form 10-Q filing for the quarter ended September 30, 2008 we added a
risk factor regarding the impact of the current economic climate on our business
generally along with updates to existing risk factors specific to our
business.
Signatures
Starting
with our Form 10-Q filing for the quarter ended September 30, 2008 we clarified
that the Company’s Chief Accounting Officer who signs the Company’s annual
report on Form 10-K and its quarterly reports on Form 10-Q is the Company’s
principal financial officer.
Schedule 14A filed July 15,
2008
Compensation Discussion and
Analysis, page 15
Elements Used to Achieve
Compensation Objectives, page 16
The
Company will continue to find ways to refine its Compensation Discussion and
Analysis in future filings. The nature of our compensation program
for Named Executive Officers, excluding our Chairman/President, is based upon
the discretion of the President. The President’s compensation is
reviewed and determined by the Compensation Committee.
Summary Compensation Table,
page 17
In future
filings, we will revise our tabular presentation, including column headings, to
conform to the Summary Compensation Table requirements in Item 402(c) of
Regulation S-K. Our July 15, 2008 filing included a typesetting error
resulting in the terms ‘Stock’ and ‘All Other’ being incorrectly shifted to the
right by one column.
In
connection with responding to your comments, we acknowledge that:
·
the
Company is responsible for the adequacy and accuracy of the disclosure in
the filing;
·
staff
comments or changes to disclosures 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 federal securities laws of
the United States.
We
believe this letter fully responds to the Staff’s inquiries. We are
available at your convenience to discuss this further should you have any
questions. Please call me at (602) 263-6804.
AMERCO,
Inc.
/s/ Jason A.
Berg
Jason A.
Berg
Chief
Accounting Officer
Principal
Financial Officer