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SEC Comment Letter for WILLIS LEASE FINANCE CORP (WLFC) (CIK 0001018164) (WLFC) — Sep 20, 2012

WILLIS LEASE FINANCE CORP (WLFC) (CIK 0001018164)
Date: Sept. 20, 2012 · CIK: 0001018164 · Accession: 0000000000-12-051594

AI Filing Summary & Sentiment

Date
December 31, 2011
Author
/s/ Rufus Decker
Form
UPLOAD
Company
WILLIS LEASE FINANCE CORP (WLFC) (CIK 0001018164)

Letter

UNITED STATES SECURITIES AND EXCHANGE COMMISSION WASHINGTON, D.C. 20549 DIVISION OF CORPORATION FINANCE September 20 , 2012 Via E -mail Mr. Bradley S. Forsyth Chief Financial Officer Willis Lease Finance Corporation 773 San Marin D rive, Suite 2215 Novato, CA 94998

RE: Willis Lease Finance Corporation Form 10 -K for the Year Ended December 31, 2011 Filed March 13, 2012 File No. 1 -15369

Dear Mr. Forsyth:

We have comp leted our review of your filing . We remind you that our comments or changes to disclosure in response to our comments do not foreclose the Commission from taking any action with resp ect to the company or the filing and the company may not assert staff comments as a defense in any proceeding initiated by the Commission o r any person under the federal securities laws of the United States. We urge all persons who are responsible for the accuracy and adequacy of the disclosure in the filing to be certain that the filing include s the information the Securities Exchange Act o f 1934 and all applicable rules require.

Sincerely,
/s/ Rufus Decker

Show Raw Text
UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549

       DIVISION OF
CORPORATION FINANCE

                                                                     September 20 , 2012

Via E -mail
Mr. Bradley S. Forsyth
Chief Financial Officer
Willis Lease Finance Corporation
773 San Marin D rive, Suite 2215
Novato, CA 94998

 RE: Willis Lease Finance Corporation
Form 10 -K for the Year Ended December 31, 2011
Filed March 13, 2012
File No. 1 -15369

Dear Mr. Forsyth:

We have comp leted our review of your filing .  We remind you that our comments or
changes to disclosure in response to our comments do not foreclose the Commission from taking
any action with resp ect to the company or the filing  and the company may not assert staff
comments as a defense in any proceeding initiated by the Commission o r any person under the
federal securities laws of the United States.  We urge all persons who are responsible for the
accuracy and adequacy of the disclosure in the filing to be certain that the filing  include s the
information the Securities Exchange Act o f 1934 and all applicable rules require.

  Sincerely,

/s/ Rufus Decker

        Rufus Decker
       Accounting Branch Chief