SecProbe.io

December 9, 2019
Robert Sanchez
Chairman and Chief Executive Officer
Ryder Sytem, Inc.
11690 N.W. 105th Street
Miami, FL 33178
Re:Ryder Sytem, Inc.
Form 10-K for the Year Ended December 31, 2018
Filed February 21, 2019
Form 10-Q for the Fiscal Quarter Ended September 30, 2019
Filed October 30, 2019
File No. 001-04364
Dear Mr. Sanchez:
            We have reviewed your filings 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 these comments within ten business days by providing the requested
information or advise us as soon as possible when you will respond.  If you do not believe our
comments apply to your facts and circumstances, please tell us why in your response.
            After reviewing your response to these comments, we may have additional comments.
Form 10-Q for the Fiscal Quarter Ended September 30, 2019
Management's Discussion and Analysis of Financial Condition and Results of Operations
Operating Results by Business Segment
Fleet Management Solutions, page 45
1.We note the substantially reduced EBT for the FMS segment for each current year period
presented relative to the corresponding prior year period, including a significant loss for
the three months ended September 30, 2019.  You attribute the reduced results to higher
depreciation resulting from changes in used vehicle residual value estimates made in the
third quarter 2019 and higher losses from used vehicle sales resulting from higher residual
value adjustments and lower expected sales prices and volumes.  In correlation with your
disclosure in “Critical Accounting Estimates” in regard to these items, please expand your
discussion of how this trend regarding residual values, depreciation, and deteriorating

 FirstName LastNameRobert Sanchez
 Comapany NameRyder Sytem, Inc.
 December 9, 2019 Page 2
 FirstName LastName
Robert Sanchez
Ryder Sytem, Inc.
December 9, 2019
Page 2
market conditions for used vehicles is expected to impact future FMS EBT in annual and
interim reporting periods.  Refer to Item 303(a)(3)(ii) and the introductory paragraph to
Item 303(b) of Regulation S-K.  To the extent appropriate and material, expand your
disclosure regarding the above noted trend to the DTS and SCS segments.
Financial Resources and Liquidity, page 51
2.Please provide a more robust analysis of the lower working capital needs contributing to
the nearly 25% increase in net cash provided by operating activities in the current interim
period compared to the corresponding prior year period.  Your analysis should explain the
reason for the lower working capital needs, and address each working capital item
materially contributing to the change and the underlying drivers associated with each.
Refer to section IV.B.1 of SEC Release No. 33-8350 for guidance.
            We remind you that the company and its management are responsible for the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action or absence of
action by the staff.
            You may contact Robert Shapiro, Senior Staff Accountant, at 202-551-3273 or Doug
Jones, Senior Staff Accountant, at 202-551-3309 if you have questions regarding comments on
the financial statements and related matters.
Sincerely,
Division of Corporation Finance
Office of Trade & Services
cc:       Scott Parker