March 8, 2011
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Confidential Treatment Request Pursuant to |
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FOIA CONFIDENTIAL TREATMENT REQUEST
VIA EDGAR AND OVERNIGHT COURIER
Division of Corporation Finance
Securities and Exchange Commission
100 F Street, N.E.
Mail Stop 4631
Washington, D.C. 20549-4631
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Attn: |
Mr. Rufus Decker |
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Accounting Branch Chief |
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Re: |
International Lease Finance Corporation |
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Form 10-K for the Year Ended December 31, 2009 |
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Forms 10-Q for the Periods Ended March 31, 2010, June 30, 2010 |
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File No. 1-31616 |
Ladies and Gentlemen:
This letter is submitted by International Lease Finance Corporation, a California corporation (the “Company”), in response to comments received from the staff of the Division of Corporation Finance (the “Staff”) of the Securities and Exchange Commission (the “SEC”) in a conversation between the Staff and the Company on March 7, 2011. The Staff’s comments related to (i) the Company’s Annual Report on Form 10-K for the year ended December 31, 2009 (the “2009 10-K”), (ii) the Company’s Quarterly Report on Form 10-Q for the quarterly period ended March 31, 2010, (iii) the Company’s Quarterly Report on Form 10-Q for the quarterly period ended June 30, 2010 and (iv) the Company’s Quarterly Report on Form 10-Q for the quarterly period ended September 30, 2010.
The Company provided a materiality assessment related to its change in accounting for the capitalized overhaul amortization period in response to the Staffs’ comment 4 in its letter to the Company dated February 24, 2011. The Company respectfully refers the Staff to Exhibit A of this letter which presents the disaggregated quantitative assessments under the iron curtain and
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Division of Corporation Finance |
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CONFIDENTIAL TREATMENT REQUESTED BY |
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Securities and Exchange Commission |
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INTERNATIONAL LEASE FINANCE CORPORATION |
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March 8, 2011 |
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rollover methods of the two significant changes in accounting for the Company’s year ended December 31, 2010: (i) the change in the amortization period of the capitalized overhauls (Exhibit A1) and (ii) the out of period adjustment for the Excess Benefit Plan (“EBP”) costs charged to the Company by its parent company AIG (Exhibit A2). Because both items were recorded in the quarters that they were identified, there are no unadjusted differences at December 31, 2010, and therefore no effect under the iron curtain method. Within the rollover method analysis, the effect of the out of period adjustments on the fourth quarter 2010 and the 2010 year as a whole is considered.
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If you have any questions or require any additional information with respect to any of the matters discussed in this letter, please call me at (310) 788-1999 or John-Paul Motley at (213) 430-6100.
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Respectfully submitted, |
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/s/ Kurt H. Schwarz |
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Kurt H. Schwarz |
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Senior Vice President and Chief Accounting Officer |
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cc: |
Mr. Frederick S. Cromer |
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Mr. Alan H. Lund |
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Mr. John-Paul Motley, Esq., O’Melveny & Myers LLP |
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Division of Corporation Finance |
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CONFIDENTIAL TREATMENT REQUESTED BY |
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Securities and Exchange Commission |
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INTERNATIONAL LEASE FINANCE CORPORATION |
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March 8, 2011 |
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Exhibit A1
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*** Indicates that certain information contained herein has been omitted and filed separately with the Securities and Exchange Commission. Confidential treatment has been requested with respect to the omitted portions.
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Division of Corporation Finance |
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CONFIDENTIAL TREATMENT REQUESTED BY |
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Securities and Exchange Commission |
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INTERNATIONAL LEASE FINANCE CORPORATION |
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March 8, 2011 |
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Exhibit A2
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*** Indicates that certain information contained herein has been omitted and filed separately with the Securities and Exchange Commission. Confidential treatment has been requested with respect to the omitted portions.