SEC Company Response from World Omni Auto Leasing LLC (CIK 0001439697) — Sep 11, 2025
World Omni Auto Leasing LLC (CIK 0001439697)
Date: Sept. 11, 2025 · CIK: 0001439697 · Accession: 0001410578-25-002093
AI Filing Summary & Sentiment
File numbers found in text: 333-289150
Referenced dates: August 27, 2025
Letter
Mayer Brown LLP
1221 Avenue of the Americas
New York, NY 10020-1001
United States of America
T: +1 212 506 2500
F: +1 212 262 1910
mayerbrown.com
September 11, 2025 Rudgee S. Charles
Partner
T: +1 212 506 2256
rcharles@mayerbrown.com
Via EDGAR
U.S. Securities and Exchange Commission
Division of Corporation Finance
Office of Structured Finance
100 F Street, N.E.
Washington, D.C. 20549
Attention: Jason Weidberg
Kayla Roberts
Re: World Omni Auto Leasing LLC
World Omni LT
Registration Statement on Form SF-3
Originally Filed July 31, 2025, File Nos. 333-289150 and 333-289150-01
Ladies and Gentlemen:
This letter is provided on behalf of World Omni Auto Leasing LLC (the “Depositor”) and World Omni LT (the “Titling Trust” and, together with the Depositor, the “Registrants”) in response to the letter dated August 27, 2025 (the “Comment Letter”) from the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”) in connection with the above-referenced registration statement and the filing of Amendment No. 1 to Form SF-3 Registration Statement with respect thereto.
The Registrants’ responses to the Staff’s comments are set forth below. The numbered paragraphs below set forth the Staff’s comments in italicized text together with the Registrants’ responses. The numbers correspond to the numbered paragraphs in the Comment Letter. Unless otherwise noted, the use of “we,” “us” and similar terms refers to the Registrants.
Registration Statement on Form SF-3
General
1. Please confirm that the depositor or any issuing entity previously established, directly or indirectly, by the depositor or any affiliate of the depositor has been current and timely with Exchange Act reporting during the last twelve months with respect to asset-backed securities involving the same asset class. Please refer to General Instruction I.A.2. of Form SF-3.
Response: We confirm that the depositor and any issuing entity previously established, directly or indirectly, by the depositor or any affiliate of the depositor have been current and timely with Exchange Act reporting during the last twelve months with respect to asset-backed securities involving the same asset class.
Mayer Brown is a global services provider comprising an association of legal practices that are separate entities including
Mayer Brown LLP (Illinois, USA), Mayer Brown International LLP (England & Wales), Mayer Brown Hong Kong LLP (a Hong Kong limited liability
partnership which operates in temporary association with Hong Kong partnership Johnson Stokes & Master)
and Tauil & Chequer Advogados (a Brazilian law partnership).
United States Securities and
Exchange Commission
Page 2
September 11, 2025
Form of Prospectus,
Underwriting, page 234
2. We note your reference to Rule 15c6-1 of the Securities Exchange Act. Please revise your disclosure to reflect the final rule amendments adopted by the Commission shortening the standard settlement cycle for broker-dealer transactions in securities from two business days after the trade date to one business day after the trade date, unless otherwise expressly agreed to by the parties at the time of the transaction. Refer to Shortening the Securities Transaction Settlement Cycle, Exchange Act Release No. 34-96930 (February 15, 2023).
Response: We have revised the disclosure to refer to one business day after the trade date, unless otherwise expressly agreed to by the parties at the time of the transaction.
We hope that the foregoing has been responsive to the Staff’s comments.
Please feel free to call me at (212) 506-2256 with any questions.
Sincerely,
/s/ Rudgee S.
Charles
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filename1.htm
Mayer Brown LLP
1221 Avenue of the Americas
New York, NY 10020-1001
United States of America
T: +1 212 506 2500
F: +1 212 262 1910
mayerbrown.com
September 11, 2025
Rudgee S. Charles
Partner
T: +1 212 506 2256
rcharles@mayerbrown.com
Via EDGAR
U.S. Securities and Exchange Commission
Division of Corporation Finance
Office of Structured Finance
100 F Street, N.E.
Washington, D.C. 20549
Attention:
Jason Weidberg
Kayla Roberts
Re: World Omni Auto Leasing
LLC
World Omni LT
Registration Statement on Form SF-3
Originally Filed July 31, 2025, File Nos. 333-289150 and 333-289150-01
Ladies and Gentlemen:
This
letter is provided on behalf of World Omni Auto Leasing LLC (the “Depositor”) and World Omni LT (the “Titling
Trust” and, together with the Depositor, the “Registrants”) in response to the letter dated August 27,
2025 (the “Comment Letter”) from the staff (the “Staff”) of the Securities and Exchange Commission
(the “Commission”) in connection with the above-referenced registration statement and the filing of Amendment No. 1
to Form SF-3 Registration Statement with respect thereto.
The
Registrants’ responses to the Staff’s comments are set forth below. The numbered paragraphs below set forth the Staff’s
comments in italicized text together with the Registrants’ responses. The numbers correspond to the numbered paragraphs in the
Comment Letter. Unless otherwise noted, the use of “we,” “us” and similar terms refers to the Registrants.
Registration Statement on Form SF-3
General
1. Please confirm that the depositor
or any issuing entity previously established, directly or indirectly, by the depositor or
any affiliate of the depositor has been current and timely with Exchange Act reporting during
the last twelve months with respect to asset-backed securities involving the same asset class.
Please refer to General Instruction I.A.2. of Form SF-3.
Response: We confirm that the
depositor and any issuing entity previously established, directly or indirectly, by the depositor or any affiliate of the depositor have
been current and timely with Exchange Act reporting during the last twelve months with respect to asset-backed securities involving the
same asset class.
Mayer Brown is a
global services provider comprising an association of legal practices that are separate entities including
Mayer Brown LLP (Illinois, USA), Mayer Brown International LLP (England & Wales), Mayer Brown Hong Kong LLP (a Hong Kong limited
liability
partnership which operates in temporary association with Hong Kong partnership Johnson Stokes & Master)
and Tauil & Chequer Advogados (a Brazilian law partnership).
United States Securities and
Exchange Commission
Page 2
September 11, 2025
Form of Prospectus,
Underwriting, page 234
2. We note your reference to Rule 15c6-1
of the Securities Exchange Act. Please revise your disclosure to reflect the final rule amendments
adopted by the Commission shortening the standard settlement cycle for broker-dealer transactions
in securities from two business days after the trade date to one business day after the trade
date, unless otherwise expressly agreed to by the parties at the time of the transaction.
Refer to Shortening the Securities Transaction Settlement Cycle, Exchange Act Release No. 34-96930
(February 15, 2023).
Response:
We have revised the disclosure to refer to one business day after the trade date, unless otherwise expressly agreed to by the parties
at the time of the transaction.
We hope that the foregoing has been responsive
to the Staff’s comments.
Please feel free to call me at (212) 506-2256
with any questions.
Sincerely,
/s/ Rudgee S.
Charles
Rudgee S. Charles
cc:
Casey L. Gunnell, Jr., World Omni Auto Leasing LLC and Auto Lease Finance LLC
Bryan Romano, World Omni Auto Leasing LLC and Auto Lease Finance LLC
Paula Pescaru, Esq., World Omni Auto Leasing LLC and Auto Lease Finance LLC
Jeffrey S. O’Connor, Counsel, Mayer Brown LLP