SecProbe.io

September 23, 2014

Via E -mail
Charles F. Avery Jr.
Chief Financial Officer
FreightCar America, Inc.
Two North Riverside Plaza, Suite 1300
Chicago, Illinois 60606

Re: FreightCar  America, Inc.
 Form 10-K for the Year Ended December 31, 2013
Filed March 14, 2014
File No. 000 -51237

Dear Mr. Avery :

We have reviewed your filing an d have the following comments.  In some of our
comments, we may ask you to provide us with information so we may better understand your
disclosure.

Please r espond to this letter within 10  business days by confirming that you will revise
your document in future filings (unless otherwise indicated ) and providing any  reque sted
information.   If you do not believe our comments apply to your facts and circumstances, please
tell us why in your response.

After reviewing the information you provide in response to these  comments, we may
have additional comments.

Form 10 -K for the Year Ended December 31, 2013

Consolidated Balance Sheets, page 38

1. Reference is made to the line item caption “Customer advance” of $19,037 at December
31, 2013.   In light of the fact this appears to be new in fiscal 2014, please describe for us
in greater detail the natur e and terms of the customer advance  and revise your notes to
disclose your accounting policy for such customer advances.  We note that you have
classified the advance and repayments within financing activities on the statements of
cash flows and based upon  disclosure contained elsewhere in the filing, such amounts
relate to customer advance s for leased railcars delivered for which revenue cannot be
recognized until all contingencies have been resolved.  In this regard, please explain to us
how non -cash impu ted interest and repayment of customer advances are recorded within
your financial statements and describe the contingencies that continue to remain
unresolved as of June 30, 2014.

Charles F. Avery Jr.
FreightCar America, Inc.
September 23, 2014
Page 2

 Notes to the Financial Statements

Note 3. Fair Value Measurements,  page 48

2. Please revise to provide the disclosures related to fair value measurements of assets
recorded at fair value on a non -recurring basis, such as the Danville facility and the
Clinton repair shop which were impaired during 2013.  See guidance in ASC  820-10-50.

3. We note from your disclosure in Note 3  you disclose financial assets recorded at fair
value on a recurring basis ; however, your disclosure in Note 2  indicates that debt
securities which you have the positive intent and ability to hold to matur ity are classified
as securities -held-to-maturity and are reported at amortized cost adjusted for amortization
of premium and accretion of discount on a level yie ld basis.  In this regard, p lease
reconcile for us the information provided in Notes 2 and 3, and clarify your disclosure s
accordingly.   Also, your notes to the financial statements should include the disclosures
set forth in ASC 320 -10-50-5 as they apply to the held -to-maturity securities.

We urge all persons who are responsible for the accurac y and adequacy of the disclosure
in the filing to be certain that the filing includes the information the Securities Exchange Act of
1934 and all applicable Exchange Act rules require.   Since the company and its management are
in possession of all facts re lating to a company’s disclosure, they are responsible for the accuracy
and adequacy of the disclosures they have made.

 In responding to our comments, please provide  a written statement from the company
acknowledging that:

 the company is responsible for the adequacy and accuracy of the disclosure in the filing;

 staff comments or changes to disclosure in response to staff comments do not foreclose
the Commission from taking any action with respect to the filing; and

 the company may not assert staff comments as a defense in any proceeding initiated by
the Commission or any person under the federal securities laws of the United States.

You may contact Claire Erlanger  at (202) 551 -3301  or Jean Yu  at (202) 551 -3305  if you
have questions regarding comments on the financial statements and related matters . You may
also contact me at (202) 551 -3813.

Sincerely,

 /s/ Linda Cvrkel

 Linda Cvrkel
Branch Chief