SecProbe.io

March 26, 2020
Charles Barrantes
Chief Financial Officer
General Finance Corporation
39 East Union Street
Pasadena, California 91103
Re:General Finance Corporation
Form 10-K for the Fiscal Year Ended June 30, 2019
Filed September 12, 2019
File No. 1-32845
Dear Mr. Barrantes:
            We have limited our review of your filing to the financial statements and related
disclosures and 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 respond to these comments 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
comments apply to your facts and circumstances, please tell us why in your response.
            After reviewing your response to these comments, we may have additional comments.
Form 10-K filed September 12, 2019
Consolidated Balance Sheets, page F-3
1.Please tell us your consideration of presenting classified balance sheets.  Refer to Rules 5-
02.9 and 5-02.21 of Regulation S-X.
Consolidated Statements of Comprehensive Income/Loss, page F-5
2.Please tell us your consideration of disclosing totals for other comprehensive income
(loss) for the years presented.  Refer to ASC 220-10-45-1B(b).
3.Please tell us your consideration of disclosing either on the face of the statements or as a
separate disclosure in the notes, the changes in the accumulated balances for each
component of other comprehensive income included in that separate component of
equity.  Refer to ASC 220-10-45-14A.

 FirstName LastNameCharles  Barrantes
 Comapany NameGeneral Finance Corporation
 March 26, 2020 Page 2
 FirstName LastNameCharles  Barrantes
General Finance Corporation
March 26, 2020
Page 2

Notes to Consolidated Financial Statements
Property, Plant and Equipment, page F-11
4.Please tell us your consideration of disclosing the amount of depreciation expense for each
year presented.  Please refer to ASC 360-10-50-1.
Lease Fleet, page F-12
5.Please tell us your consideration of disclosing accumulated depreciation at each balance
sheet date and the amount of depreciation expense for each year presented.  Please refer to
ASC 360-10-50-1.
Intangible Assets, page F-14
6.Please tell us your consideration of disclosing amortization expense for each year
presented.  Please refer to ASC 350-30-50-2.
Contract Costs and Liabilities, page F-16
7.Please tell us your consideration of providing a tabular reconciliation of the changes in
the aggregate product warranty liability at each balance sheet date, including the:

•beginning balance of the aggregate product warranty liability;
•aggregate reductions in that liability for payments made under the warranty;
•aggregate changes in the liability for accruals related to product warranties issued
during the reporting period;
•aggregate changes in the liability for accruals related to preexisting warranties; and
•ending balance of the aggregate product warranty liability.

Please refer to ASC 460-10-50-8.
Note 5. Senior and Other Debt
Senoir Notes, page S-1
8.We note the Indenture limit the Company's ability to pay dividends and that you provided
Schedule I.  Please tell us your consideration of disclosing the most significant restrictions
on the payment of dividends, their pertinent provisions and the amount of retained
earnings or net income restricted or free of restrictions and the amount of restricted net
assets of unconsolidated subsidiaries and consolidated subsidiaries as of June 30, 2019.
Refer to Rule 4-08(e)(1) and (3)(i) and (ii) of Regulation S-X.
            In closing, 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
absence of action by the staff.

 FirstName LastNameCharles  Barrantes
 Comapany NameGeneral Finance Corporation
 March 26, 2020 Page 3
 FirstName LastName
Charles  Barrantes
General Finance Corporation
March 26, 2020
Page 3
            You may contact Tony Watson at (202) 551-3318 or Bill Thompson at (202) 551-
3344 with any questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services