CORRESP Filing
WILLIS LEASE FINANCE CORP
Date: May 13, 2025 · CIK: 0001018164 · Accession: 0001193125-25-118800
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 333-286998
Letter
Re: Willis Lease Finance Corporation Registration Statement on Form S-3 Filed May 6, 2025 File No. 333-286998 REQUEST FOR ACCELERATION OF EFFECTIVENESS Acceleration Request Requested Date: May 15, 2025 Requested Time: 4:01 p.m. Eastern Time Ladies and Gentlemen: Pursuant to Rule 461 promulgated under the Securities Act of 1933, as amended, Willis Lease Finance Corporation (the “ Company ”) hereby requests that the Securities and Exchange Commission (the “ Commission ”) take appropriate action to declare the Company’s Registration Statement on Form S - 3 (File No. 333-286998) effective at the “Requested Date” and “Requested Time” set forth above or as soon thereafter as practicable. The Company hereby authorizes Albert Vanderlaan, who is an attorney with the Company’s outside legal counsel, Orrick, Herrington & Sutcliffe LLP, to orally modify or withdraw this request for acceleration. The Company requests that it be notified of such effectiveness by a telephone call to Mr. Vanderlaan at (617) 880-2219. [Signature page follows] 4700 Lyons Technology Parkway | Coconut Creek, Florida 33073 USA +1 561.349.9989 | www.wlfc.global
May 13, 2025 VIA EDGAR U.S. Securities and Exchange Commission Division of Corporation Finance 100 F Street, N.E. Washington, D.C. 20549
Attn: Kate Beukenkamp
Sincerely,
WILLIS LEASE FINANCE CORPORATION
By:
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CORRESP 1 filename1.htm CORRESP May 13, 2025 VIA EDGAR U.S. Securities and Exchange Commission Division of Corporation Finance 100 F Street, N.E. Washington, D.C. 20549 Attn: Kate Beukenkamp Re: Willis Lease Finance Corporation Registration Statement on Form S-3 Filed May 6, 2025 File No. 333-286998 REQUEST FOR ACCELERATION OF EFFECTIVENESS Acceleration Request Requested Date: May 15, 2025 Requested Time: 4:01 p.m. Eastern Time Ladies and Gentlemen: Pursuant to Rule 461 promulgated under the Securities Act of 1933, as amended, Willis Lease Finance Corporation (the “ Company ”) hereby requests that the Securities and Exchange Commission (the “ Commission ”) take appropriate action to declare the Company’s Registration Statement on Form S - 3 (File No. 333-286998) effective at the “Requested Date” and “Requested Time” set forth above or as soon thereafter as practicable. The Company hereby authorizes Albert Vanderlaan, who is an attorney with the Company’s outside legal counsel, Orrick, Herrington & Sutcliffe LLP, to orally modify or withdraw this request for acceleration. The Company requests that it be notified of such effectiveness by a telephone call to Mr. Vanderlaan at (617) 880-2219. [Signature page follows] 4700 Lyons Technology Parkway | Coconut Creek, Florida 33073 USA +1 561.349.9989 | www.wlfc.global Sincerely, WILLIS LEASE FINANCE CORPORATION By: /s/ Z. Clifton Dameron IV Name: Z. Clifton Dameron IV Title: Senior Vice President cc: Scott Flaherty, Willis Lease Finance Corporation Ellen Ehrenpreis, Esq., Orrick, Herrington & Sutcliffe LLP Albert Vanderlaan, Esq., Orrick, Herrington & Sutcliffe LLP 4700 Lyons Technology Parkway | Coconut Creek, Florida 33073 USA +1 561.349.9989 | www.wlfc.global