John-Paul Motley
T: +1 213 561 3204
jpmotley@cooley.com
VIA EDGAR
May 28, 2025
U.S. Securities and Exchange Commission
Division of Corporation Finance
Office of Trade & Services
100 F Street, N.E.
Washington, D.C. 20549
Attn: Suying Li, Rufus Decker
| Re: | Air Lease Corporation |
Form 10-K for Fiscal Year Ended December 31, 2024
File No. 001-35121
Ladies and Gentlemen:
On behalf of our client, Air Lease Corporation (the “Company”), we submit this letter in response to the verbal comments (the “Verbal Comments”) received in a telephone conversation between the Company and the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”) on May 15, 2025 regarding the Company’s response to Comments #1 and #2 in the Company’s letter dated May 7, 2025, responding to the letter dated April 30, 2025 from the Staff to the Company commenting on the Company’s Annual Report on Form 10-K for the fiscal year ended December 31, 2024, filed with the Commission on February 13, 2025. Set forth below is the Company’s response to the Verbal Comments. The Staff’s Verbal Comments are repeated in bold and are followed by the Company’s responses.
Verbal Comments of the Staff communicated on May 15, 2025
| 1. | For the Company’s presentation of “Other assets” in its consolidated balance sheets, the Staff will not object to the presentation if it is revised to disclose, as separate line items, the Company’s flight equipment held for sale and net investment in sales-type leases. Similarly, for the Company’s presentation of “Security deposits and maintenance reserves on flight equipment leases” in its consolidated balance sheets, the Staff will not object to the presentation if it revised to disclose “Security deposits on flight equipment leases” and “Maintenance reserves on flight equipment leases” as separate line items. |
Beginning with the Company’s Quarterly Report on Form 10-Q for the period ended June 30, 2025 and in future filings with the Commission, the Company will present flight equipment held for sale, net investment in sales-type leases, security deposits on flight equipment leases and maintenance reserves on flight equipment leases as separate line items on its consolidated balance sheets. In addition, the Company will include footnote disclosure showing the disaggregated components included in “Other assets” and “Accrued interest and other payables” in the Company’s consolidated balance sheets. Please refer to Appendix A for the proposed revised disclosures.
| 2. | For the Company’s presentation of “Revenues” in its consolidated statements of income and other comprehensive income, the Staff will not object to the presentation if it is revised to (i) disaggregate, as separate line items, “Lease rentals” and “Maintenance rentals and other receipts” within the Company’s “Rental of flight equipment” line item, and (ii) the caption is revised from “Revenues” to “Revenues and other income.” |
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