March 4, 2020

Jason Berg
Chief Financial Officer
AMERCO
5555 Kietzke Lane
Reno, Nevada 89511

       Re: AMERCO
           Form 10-K for the Fiscal Year Ended March 31, 2019
           Filed May 29, 2019
           File No. 1-11255

Dear Mr. Berg:

       We have reviewed your filing 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 10-K for the Fiscal Year Ended March 31, 2019

Consolidated statements of Comprehensive Income (Loss), page F-4

1.    Please tell us your consideration of presenting a total amount for other
comprehensive
      income as required by ASC 220-10-45-1A.
Notes to Consolidated Financial Statements, page F-8

2.    Please tell us your consideration of presenting the changes in the
accumulated balances
      for each component of accumulated other comprehensive income and
separately for each
      component of other comprehensive income. In addition, please tell us your
consideration
      of presenting current period reclassifications out of accumulated other
comprehensive
      income and other amounts of current-period other comprehensive income and
the amount
      of income tax expense or benefit allocated to each component of other
comprehensive
      income, including reclassification adjustments, as required by
220-10-45-14A. Please
      also refer to ASC 220-10-55-15.
 Jason Berg
AMERCO
March 4, 2020
Page 2
Note 3. Accounting Policies
Deferred Policy Acquisition Costs, page F-13

3.       Please clarify that you only capitalize direct costs associated with
successful efforts to
         acquire new or renewal policies. Refer to ASC 944-30-50-1. In
addition, please tell us
         your consideration of disclosing deferred policy acquisition costs
amortization policies for
         each product type.
Note 20. Statutory Financial Information of Insurance Subsidiaries, page F-41

4.       We note your disclosure of statutory surplus that could be distributed
as ordinary
         dividends. We also note that you have provided Schedule I. If
material, please
         disclose the nature of any other restrictions on the ability of
consolidated subsidiaries to
         transfer funds to you in the form of cash dividends, loans or
advances. Please also
         disclose the amounts of restricted net asset as of the end of the most
recently completed
         fiscal year. Refer to Rule 4-08(e)(3) of Regulation S-X.
Signatures, page 49

5.       The report must also be signed on behalf of the registrant by its
principal executive officer
         and principal accounting officer. Any person who occupies more than
one of the specified
         positions shall indicate each capacity in which he or she signs the
report. Refer to General
         Instruction D of Form 10-K.
        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 Adam Phippen at (202) 551-3336 or Bill Thompson at (202)
551-3344
with any questions.



FirstName LastNameJason Berg                                    Sincerely,
Comapany NameAMERCO
                                                                Division of
Corporation Finance
March 4, 2020 Page 2                                            Office of Trade
& Services
FirstName LastName