United States securities and exchange commission logo
November 25, 2020
Aengus Kelly
Chief Executive Officer
AerCap Holdings N.V.
AerCap House
65 St. Stephen s Green
Dublin D02 YX20
Ireland
Re: AerCap Holdings
N.V.
Form 20-F for
Fiscal Year Ended December 31, 2019
Filed March 5, 2020
File No. 001-33159
Dear Mr. Kelly:
We have limited our review of your filing to the financial
statements and related
disclosures and have the 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 these comments within ten business days by
providing the requested
information or advise us as soon as possible when you will respond. If
you do not believe our
comments apply to your facts and circumstances, please tell us why in
your response.
After reviewing your
response to these comments, we may have additional comments.
Form 20-F for Fiscal Year Ended December 31, 2019
Consolidated Statements of Cash Flows, page F-9
1. Please tell us your
basis under GAAP for classifying receipts and returns of security
deposits and
maintenance payments as financing activities in your statements of cash
flows.
Note 3. Summary of Significant Accounting Policies
Flight equipment held for operating leases, net, page F-14
2. You disclose that
flight equipment is depreciated over the estimated useful life of aircraft,
which is generally 25
years from the date of manufacture, or a different period depending
on your disposition
strategy. Please tell us the extent to which your portfolio was
Aengus Kelly
FirstName LastNameAengus Kelly
AerCap Holdings N.V.
Comapany 25,
November NameAerCap
2020 Holdings N.V.
November
Page 2 25, 2020 Page 2
FirstName LastName
depreciated over a period other than its estimated useful life, the
average depreciation
period for such equipment, and whether equipment subject to this
different depreciation
term are based on the class of aircraft or other factors. Please also
tell us whether there
are situations in which the disposition strategy that results in a
different depreciation term
is known at the inception of your ownership of the equipment.
Maintenance rights and lease premium, net, page F-15
3. We note your use of the term end of lease (EOL) contracts. Please tell
us whether this
refers to separate contracts with your customers or simply to a subset
of provisions within
your lease agreements that relate to the end of the lease term.
Please explain to us the distinction between EOL contracts and MR
contracts in the
context described in the second paragraph of this footnote.
You state that you recognize leasing expenses upon lease termination
when the EOL
contract maintenance assets exceeds the EOL cash received. Please tell
us your basis for
recognizing the write-off of your EOL contract maintenance asset upon
lease termination
rather than at or over some earlier period of the lease, such as when
you determine it is not
probable that the EOL cash received will cover the EOL contract
maintenance asset or
over the last expected maintenance cycle. Please also describe for us
the circumstances in
which EOL cash compensation exceeds the EOL contract maintenance
rights asset.
Accrued maintenance liability, page F-17
4. Please explain to us how the second and third sentences of the first
paragraph of this note
relate to your accrued maintenance liability account.
In the second paragraph you state that you may be obligated to make
additional payments
to the lessee. Please tell us what these payments are in addition to.
In the second paragraph you disclose that for all lease contracts,
lessor maintenance
contributions are recognized as leasing expenses when incurred. Please
define when
incurred. Please also tell us whether you recognize a maintenance
liability for lessor
maintenance contributions for lease arrangements entered into other
than those related to
purchases of aircraft with a lease attached. If so, please describe
for us such
circumstances and when you recognize the liability.
Note 5. Flight equipment held for operating leases, net, page F-21
5. We note from your Form 6-K filed November 10, 2020, that you have
observed an
increased number of airlines shifting away from certain classes of
aircraft in favor of
others. Please disclose balances and accumulated depreciation of major
classes of
equipment held for operating lease at the balance sheet date. Refer to
ASC 842-30-50-13
and ASC 360-10-50-1.
Aengus Kelly
AerCap Holdings N.V.
November 25, 2020
Page 3
In closing, we remind you that the company and its management are
responsible for the
accuracy and adequacy of their disclosures, notwithstanding any review,
comments, action or
absence of action by the staff.
You may contact Patrick Kuhn at (202) 551-3308 or Lyn Shenk at (202)
551-3380 with
any questions.
FirstName LastNameAengus Kelly Sincerely,
Comapany NameAerCap Holdings N.V.
Division of
Corporation Finance
November 25, 2020 Page 3 Office of Trade &
Services
FirstName LastName