Mail Stop 3628 January 31, 2019 Sheli Fitzgerald Chief Executive Officer and President 801 Cherry Street, Suite 3500 Fort Worth, Texas 76102 Re: GMF Leasing LLC ACAR Leasing Ltd. Registration Statement on Form SF-3 Filed December 28, 2018 File Nos. 333-229068 and 333-229068-01 Dear Ms. Fitzgerald: This is to advise you that we have not reviewed and will not review your registration statement. Please refer to Rules 460 and 461 regarding requests for acceleration. 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. Please contact Kayla Roberts at (202) 551-3490 or me at (202) 551-3262 with any questions. Sincerely, /s/ Arthur C. Sandel Arthur C. Sandel Special Counsel Office of Structured Finance cc: John P. Keiserman, Esq. Katten Muchin Rosenman LLP Trey Brown, Esq. GM Financial