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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

Date
March 31, 2008
Author
Not clearly detected
Form
CORRESP
Company
U-Haul Holding Co /NV/ (UHAL, UHAL-B) (CIK 0000004457)

Letter

VIA EDGAR Division of Corporation Finance Securities and Exchange Commission Re: AMERCO Form 10-K for the Fiscal Year ended March 31, 2008, Filed June 4, 2008 Schedule 14A filed July 15, 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

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,

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

Show Raw Text
CORRESP
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    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