SEC Comment Letter for WILLIS LEASE FINANCE CORP (WLFC) (CIK 0001018164) (WLFC) — Dec 15, 2017
WILLIS LEASE FINANCE CORP (WLFC) (CIK 0001018164)
Date: Dec. 15, 2017 · CIK: 0001018164 · Accession: 0000000000-17-043763
AI Filing Summary & Sentiment
Letter
Mail Stop 4631 December 15, 2017 Via E -mail Mr. Scott B. Flaherty Chief Financial Officer Willis Lease Finance Corporation 773 San Marin Drive, Suite 2215 Novato , CA 94998
Re: Willis Lease Finance Corporation Form 10 -K for the Fiscal Year Ended December 31, 20 16 Filed March 16, 2017 File No. 1-15369
Dear Mr. Flaherty :
We have reviewed your filing and have the following comment. In some of our comments, we may ask you to provide us with information so we may better understand your disclosure.
Please respond to th is 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 appl ies to your facts and circumstances, please tell us why in your response.
After reviewing your response and any amendment you may file in response to th is comment, we may have additional comments.
Form 10 -K for the Fiscal Year Ended December 31, 2016
Critical Accounting Policies and Estimates, page 28 Asset Valuation, page 28
1. We note that you “rely on leading accredited third -party appraisers for independent appraisals of current fair value.” Please tell us the nature and extent of their involvement in determining fair value of your aircraft engines and related equipment. To the extent that you discuss third party appraisers and your disclosure elevates their participation to that of an expert you relied upon, you shoul d name the appraiser and file a consent since your Form 10 -K is incorporated by reference into your previously filed Form S -8. Refer to Item 601(B)(23) of Regulation S -K.
Mr. Scott B. Flaherty Willis Lease Finance Corporation December 15, 2017 Page 2
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 a bsence of action by the staff.
You may contact Dale Welcome at (202) 551 -3865 or Jeanne Baker at (202) 551 -3691 with any questions.
Sincerely,
/s/ W. John Cash
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Mail Stop 4631 December 15, 2017 Via E -mail Mr. Scott B. Flaherty Chief Financial Officer Willis Lease Finance Corporation 773 San Marin Drive, Suite 2215 Novato , CA 94998 Re: Willis Lease Finance Corporation Form 10 -K for the Fiscal Year Ended December 31, 20 16 Filed March 16, 2017 File No. 1-15369 Dear Mr. Flaherty : We have reviewed your filing and have the following comment. In some of our comments, we may ask you to provide us with information so we may better understand your disclosure. Please respond to th is 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 appl ies to your facts and circumstances, please tell us why in your response. After reviewing your response and any amendment you may file in response to th is comment, we may have additional comments. Form 10 -K for the Fiscal Year Ended December 31, 2016 Critical Accounting Policies and Estimates, page 28 Asset Valuation, page 28 1. We note that you “rely on leading accredited third -party appraisers for independent appraisals of current fair value.” Please tell us the nature and extent of their involvement in determining fair value of your aircraft engines and related equipment. To the extent that you discuss third party appraisers and your disclosure elevates their participation to that of an expert you relied upon, you shoul d name the appraiser and file a consent since your Form 10 -K is incorporated by reference into your previously filed Form S -8. Refer to Item 601(B)(23) of Regulation S -K. Mr. Scott B. Flaherty Willis Lease Finance Corporation December 15, 2017 Page 2 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 a bsence of action by the staff. You may contact Dale Welcome at (202) 551 -3865 or Jeanne Baker at (202) 551 -3691 with any questions. Sincerely, /s/ W. John Cash W. John Cash Accounting Branch Chief Office of Manufacturing and Construction