SEC Comment Letter for AIR LEASE CORP (AL) (CIK 0001487712) (AL) — Apr 10, 2012
AIR LEASE CORP (AL) (CIK 0001487712)
Date: April 10, 2012 · CIK: 0001487712 · Accession: 0000000000-12-018161
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UNITED STATES SECURITIES AND EXCHANGE COMMISSION WASHINGTON, D.C. 20549-4631 DIVISION OF CORPORATION FINANCE April 10, 2012 Via Facsimile Mr. Gregory B. Willis Chief Financial Officer Air Lease Corporation 2000 Avenue of the Stars, Suite 1000N Los Angeles, CA 90067
Re: Air Lease Corporation Form 10-K for the Fiscal Year Ended December 31, 2011 Filed March 9, 2012 File No. 1-35121
Dear Mr. Willis: We have reviewed your response and have th e 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 this letter within ten business days by amending your filing, by providing the requested information, or by advi sing us when you will provide the requested response. If you do not believe our comments apply to your fact s and circumstances or do not believe an amendment is appropriate, please tell us why in your response. After reviewing any amendment to your filing and the information you provide in response to these comments, we may have additional comments.
Form 10-K for Fiscal Year Ended December 31, 2011
Financial Statements
Note 1 – Summary of Significant Accounting Policies
Rental of flight equipment, page 65
1. We note your response to our prior comment . Please provide us with additional information regarding your l ease agreements that contain nonperformance related default covenants, material adverse change clau ses and cross-defaul t provisions. Please specifically address the following:
Mr. Gregory B. Willis Air Lease Corporation April 10, 2012 Page 2
Tell us how you evaluated each provisi on based on the guidance found in ASC 840-10-25-14 and tell us whether any of your agreements include provisions that fail to meet the criter ia in this paragraph. To the extent that any of your agreements include covenants or provisions that are subjectively determinable or otherwise do not meet the criteria of ASC 840-10- 25-14, tell us whether you have included the maximum amount the lessee could be required to pay in determining mi nimum lease payments for purposes of applying ASC 840-10-25-1(d) and explain how you dete rmined such amounts.
You may contact Kevin Stert zel at (202) 551-3723, or A nne McConnell at (202) 551- 3709, if you have questions regarding comments on th e financial statements and related matters. Please contact me at (202) 551-3768 with any other questions. S i n c e r e l y , /s/ W. John Cash W. John Cash B r a n c h C h i e f
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UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-4631
DIVISION OF
CORPORATION FINANCE
April 10, 2012
Via Facsimile
Mr. Gregory B. Willis Chief Financial Officer Air Lease Corporation 2000 Avenue of the Stars, Suite 1000N Los Angeles, CA 90067
Re: Air Lease Corporation
Form 10-K for the Fiscal Year Ended December 31, 2011
Filed March 9, 2012 File No. 1-35121
Dear Mr. Willis:
We have reviewed your response and have th e 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 this letter within ten business days by amending your filing, by
providing the requested information, or by advi sing us when you will provide the requested
response. If you do not believe our comments apply to your fact s and circumstances or do not
believe an amendment is appropriate, please tell us why in your response.
After reviewing any amendment to your filing and the information you provide in
response to these comments, we may have additional comments.
Form 10-K for Fiscal Year Ended December 31, 2011
Financial Statements
Note 1 – Summary of Significant Accounting Policies
Rental of flight equipment, page 65
1. We note your response to our prior comment . Please provide us with additional
information regarding your l ease agreements that contain nonperformance related default
covenants, material adverse change clau ses and cross-defaul t provisions. Please
specifically address the following:
Mr. Gregory B. Willis
Air Lease Corporation April 10, 2012 Page 2
Tell us how you evaluated each provisi on based on the guidance found in ASC
840-10-25-14 and tell us whether any of your agreements include provisions that
fail to meet the criter ia in this paragraph.
To the extent that any of your agreements include covenants or provisions that are
subjectively determinable or otherwise do not meet the criteria of ASC 840-10-
25-14, tell us whether you have included the maximum amount the lessee could
be required to pay in determining mi nimum lease payments for purposes of
applying ASC 840-10-25-1(d) and explain how you dete rmined such amounts.
You may contact Kevin Stert zel at (202) 551-3723, or A nne McConnell at (202) 551-
3709, if you have questions regarding comments on th e financial statements and related matters.
Please contact me at (202) 551-3768 with any other questions. S i n c e r e l y , /s/ W. John Cash W. John Cash B r a n c h C h i e f