SEC Comment Letter for AIR LEASE CORP (AL) (CIK 0001487712) (AL) — May 5, 2015

AIR LEASE CORP (AL) (CIK 0001487712)
Date: May 5, 2015 · CIK: 0001487712 · Accession: 0000000000-15-024668

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AI Filing Summary & Sentiment

Sentiment

Urgency

Document Type

Confidence

SEC Posture

Company Posture

Summary

Reasoning

Date

December 31, 2014

Author

/s/ W. John Cash

Form

UPLOAD

Company

AIR LEASE CORP (AL) (CIK 0001487712)

Letter

UNITED STATES SECURITIES AND EXCHANGE COMMISSION WASHINGTON, D.C. 20549 -4631 DIVISION OF CORPORATION FINANCE May 5 , 2015 Via E -mail Mr. Gregory B. Willis Chief Financial Officer Air Lease Corp. 2000 Avenue of the Stars, Suite 1000N Los Angeles, CA 90067

Re: Air Lease Corp. Form 10-K for Fiscal Year Ended December 31, 2014 Filed February 26, 2015 File No. 1-35121

Dear Mr. Willis :

We have completed our review of your filing. We remind you that our comments or changes to disclosure in response to our comments do not foreclose the Commission from taking any action with respect to the company or 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. We urge all persons who are responsible for the accuracy 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 rules require.

Sincerely,
/s/ W. John Cash

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UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C.  20549 -4631

DIVISION OF
CORPORATION FINANCE
 May 5 , 2015

Via E -mail
Mr. Gregory B. Willis
Chief Financial Officer
Air Lease Corp.
2000 Avenue of the Stars, Suite 1000N
Los Angeles, CA  90067

 Re: Air Lease Corp.
  Form 10-K for Fiscal Year Ended December 31, 2014
Filed February 26, 2015
  File No.  1-35121

Dear Mr.  Willis :

We have completed our review of your filing.  We remind you that our comments or
changes to disclosure in response to our comments do not foreclose the Commission from taking
any action with respect to the company or 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.  We urge all persons who are responsible for the
accuracy 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 rules require.

Sincerely,

/s/ W. John Cash

W. John Cash
Branch Chief

SecProbe.io