CORRESP 1 filename1.htm accelerationrequest.htm

 

August 26, 2010
Securities and Exchange Commission
Division of Corporation Finance
100 F Street NE
Mail Stop 3561
Washington, D.C. 20549

 
 
 
Re:
BMW Auto Leasing LLC and Financial Services Vehicle Trust (each, a “Registrant”) Registration Statement on Form S-3, File No. 333-166296
 
Ladies and Gentlemen:

Pursuant to Rule 461 promulgated under the Securities Act of 1933, as amended, the Registrants hereby request that the effective date for the above-referenced Registration Statement on Form S-3 be accelerated so that it will be declared effective at 10:00 a.m., Eastern Standard Time, on Monday, August 30, 2010, or as soon as thereafter as practicable.

The Registrants acknowledge that (1) the disclosure in the filing is the responsibility of the Registrants, (2) should the Securities and Exchange Commission (the “Commission”) or the staff, acting pursuant to delegated authority, declare the filing effective, it does not foreclose the Commission from taking any action with respect to the filing, (3) the action of the Commission or the staff, acting pursuant to delegated authority, in declaring the filing effective, does not relieve the Registrants from their full responsibility for the adequacy and accuracy of the disclosure in the filing and (4) it will not assert staff comments and the declaration of effectiveness as a defense in any proceeding initiated by the Commission or any person under the securities laws of the United States.  In making this request, each of the Registrants hereby confirms that it is aware of its obligations under the Act and the Securities Exchange Act of 1934, as amended.

 
  Very Truly Yours,
     
  BMW AUTO LEASING LLC, as Registrant
     
     
  By: /s/ Joachim Herr                                
    Name:  Joachim Herr
    Title:   Treasurer
     
     
  FINANCIAL SERVICES VEHICLE TRUST, as Registrant
     
 
By: BMW Financial Services NA, LLC
     
  By: /s/ Edward A. Robinson                     
   
Name: Edward A. Robinson
   
Title: President & Chief Executive Officer