SEC Comment Letter for RYDER SYSTEM (R) — Dec 3, 2020
RYDER SYSTEM INC
Date: Dec. 3, 2020 · CIK: 0000085961 · Accession: 0000000000-20-011585
AI Filing Summary & Sentiment
File numbers found in text: 001-04364
Letter
United States securities and exchange commission logo December 3, 2020 Scott T. Parker Executive Vice President and Chief Financial Officer Ryder System, Inc. 11690 N.W. 105th Street Miami, Florida 33178 Re:Ryder System, Inc. Form 10-K for Fiscal Year Ended December 31, 2019 Filed February 27, 2020 File No. 001-04364 Dear Mr. Parker: We have limited our review of your filing to the financial statements and related disclosures and have the following comment. In our comment, we may ask you to provide us with information so we may better understand your disclosure. Please respond to this comment 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 comment applies to your facts and circumstances, please tell us why in your response. After reviewing your response to this comment, we may have additional comments. Form 10-K for Fiscal Year Ended December 31, 2019 Notes to Consolidated Financial Statements Note 7. Revenue Earning Equipment, Net, page 94 1.We note that you disclose cost and accumulated depreciation for revenue earning equipment held for operating lease by product offering categories ChoiceLease and Commercial rental. We note your review of the estimated residual values and useful lives of revenue earning equipment is based on vehicle class, generally subcategories of trucks, tractors and trailers by weight and usage. We also note that in the second quarter of 2020, you lowered your estimated residual values primarily for your truck fleet, and to a lesser extent, your tractor fleet, effective April 1, 2020.
Please disclose balances and accumulated depreciation of major classes of revenue earning equipment held for operating lease at the balance sheet date. Refer to ASC 842- 30-50-13 and ASC 360-10-50-1.
FirstName LastNameScott T. Parker Comapany NameRyder System, Inc. December 3, 2020 Page 2 FirstName LastName Scott T. Parker Ryder System, Inc. December 3, 2020 Page 2
In closing, 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 Stephen Kim at 202-551-3291 or Lyn Shenk at 202-551-3380 with any questions. Sincerely, Division of Corporation Finance Office of Trade & Services
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United States securities and exchange commission logo
December 3, 2020
Scott T. Parker
Executive Vice President and Chief Financial Officer
Ryder System, Inc.
11690 N.W. 105th Street
Miami, Florida 33178
Re:Ryder System, Inc.
Form 10-K for Fiscal Year Ended December 31, 2019
Filed February 27, 2020
File No. 001-04364
Dear Mr. Parker:
We have limited our review of your filing to the financial statements and related
disclosures and have the following comment. In our comment, we may ask you to provide us
with information so we may better understand your disclosure.
Please respond to this comment 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
comment applies to your facts and circumstances, please tell us why in your response.
After reviewing your response to this comment, we may have additional comments.
Form 10-K for Fiscal Year Ended December 31, 2019
Notes to Consolidated Financial Statements
Note 7. Revenue Earning Equipment, Net, page 94
1.We note that you disclose cost and accumulated depreciation for revenue earning
equipment held for operating lease by product offering categories ChoiceLease and
Commercial rental. We note your review of the estimated residual values and useful lives
of revenue earning equipment is based on vehicle class, generally subcategories of trucks,
tractors and trailers by weight and usage. We also note that in the second quarter of 2020,
you lowered your estimated residual values primarily for your truck fleet, and to a lesser
extent, your tractor fleet, effective April 1, 2020.
Please disclose balances and accumulated depreciation of major classes of revenue
earning equipment held for operating lease at the balance sheet date. Refer to ASC 842-
30-50-13 and ASC 360-10-50-1.
FirstName LastNameScott T. Parker
Comapany NameRyder System, Inc.
December 3, 2020 Page 2
FirstName LastName
Scott T. Parker
Ryder System, Inc.
December 3, 2020
Page 2
In closing, 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 Stephen Kim at 202-551-3291 or Lyn Shenk at 202-551-3380 with any
questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services