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
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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