SEC Comment Letter for WILLIS LEASE FINANCE CORP (WLFC) (CIK 0001018164) (WLFC) — Feb 26, 2010
WILLIS LEASE FINANCE CORP (WLFC) (CIK 0001018164)
Date: Feb. 26, 2010 · CIK: 0001018164 · Accession: 0000000000-10-011294
AI Filing Summary & Sentiment
File numbers found in text: 001-15369
Referenced dates: January 28, 2010
Letter
UNITED STATES SECURITIES AND EXCHANGE COMMISSION WASHINGTON, D.C. 20549-4631 DIVISION OF CORPORATION FINANCE Mail Stop 4631 February 26, 2010 Mr. Bradley S. Forsyth Senior Vice President and Chief Financial Officer Willis Lease Finance Corporation 773 San Marin Drive, Suite 2215 Novato, CA 94998 RE: Form 10-K for the year ended December 31, 2008 Definitive Proxy Statement on Sc hedule 14A filed on April 29, 2009 File No. 001-15369
Dear Mr. Forsyth: We have reviewed the above-referenced filings and have the following comments. Definitive Proxy Statement on Schedule 14A filed on April 29, 2009
1. We note your response to comment 5 in our letter dated January 28, 2010. From your response to comment 12 in our lett er dated December 3, 2009, we note that you benchmark annual cash compensati on against a percentage of the 75th percentile of the market. Please revise your disclosure to address where each named executive officer’s actual annual compensation fell relative to his respective benchmark and explain why cash compensation amounts exceeded or fell short of these benchmarks.
Please respond to these comments within 10 business days, or tell us when you will provide us with a response. Please provi de us with a response letter that keys your responses to our comments and provides a ny requested information. Detailed letters greatly facilitate our review. Please file your supplemental response on EDGAR as a correspondence file. Please understand that we may have additional comments after reviewing your responses to our comments.
Mr. Bradley S. Forsyth Willis Lease Finance Corporation February 26, 2010 Page 2
You may contact Hagen Gane m, Staff Attorney, at (202) 551-3330 or, in his absence, Andrew Schoeffler, Senior Staff Attorney, at (202) 551-3748 if you have any questions.
Sincerely,
Pamela A. Long
Assistant Director
Show Raw Text
UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-4631
DIVISION OF
CORPORATION FINANCE
Mail Stop 4631
February 26, 2010
Mr. Bradley S. Forsyth Senior Vice President and Chief Financial Officer Willis Lease Finance Corporation 773 San Marin Drive, Suite 2215 Novato, CA 94998
RE: Form 10-K for the year ended December 31, 2008
Definitive Proxy Statement on Sc hedule 14A filed on April 29, 2009
File No. 001-15369
Dear Mr. Forsyth:
We have reviewed the above-referenced filings and have the following comments.
Definitive Proxy Statement on Schedule 14A filed on April 29, 2009
1. We note your response to comment 5 in our letter dated January 28, 2010. From
your response to comment 12 in our lett er dated December 3, 2009, we note that
you benchmark annual cash compensati on against a percentage of the 75th
percentile of the market. Please revise your disclosure to address where each
named executive officer’s actual annual compensation fell relative to his respective benchmark and explain why cash compensation amounts exceeded or
fell short of these benchmarks.
Please respond to these comments within 10 business days, or tell us when you
will provide us with a response. Please provi de us with a response letter that keys your
responses to our comments and provides a ny requested information. Detailed letters
greatly facilitate our review. Please file your supplemental response on EDGAR as a correspondence file. Please understand that we may have additional comments after reviewing your responses to our comments.
Mr. Bradley S. Forsyth
Willis Lease Finance Corporation February 26, 2010 Page 2
You may contact Hagen Gane m, Staff Attorney, at (202) 551-3330 or, in his
absence, Andrew Schoeffler, Senior Staff Attorney, at (202) 551-3748 if you have any
questions.
Sincerely,
Pamela A. Long
Assistant Director