WILLIS LEASE FINANCE CORP

Rule 10b5-1 Trading Plans

During the quarter ended June 30, 2024, none of the Company’s Section 16 officers or directors informed us of theadoption, modification, ortermination of a “Rule 10b5-1 trading arrangement” or a “non-Rule 10b5-1 trading arrangement,” as those terms are defined in Regulation S-K, Item 408. On March 27, 2024, Brian Hole, President, adopted a Rule 10b5-1 trading arrangement, which became effective June 27, 2024, that is intended to satisfy the affirmative defense of Rule 10b5-1 for the sale of up to 13,258 shares of the Company’s common stock until June 27, 2025.

(1) Except as indicated by footnote, each trading arrangement marked as a “Rule 10b5-1 Trading Arrangement” is intended to satisfy the affirmative defense of Rule 10b5-1(c), as amended (the “Rule”).

(2) Except as indicated by footnote, each trading arrangement permitted or permits transactions through and including the earlier to occur of (a) the completion of all purchases or sales or (b) the date listed in the table. Each trading arrangement marked as a “Rule 10b5-1 Trading Arrangement” only permitted or only permits transactions upon expiration of the applicable mandatory cooling-off period under the Rule.

(3) Brian Hole’s trading plan provides for the sale of up to 13,258 shares of the Company’s common stock, subject to price and volume limits.

(4) The arrangement also provides for automatic termination in the event of completion of all sales contemplated under the trading arrangement, Brian Hole’s death or legal incapacity, written notice from Brian Hole of termination of the trading arrangement, determination by the broker that the trading arrangement has been terminated or that a breach by Brian Hole has occurred, or upon the broker’s exercise of its termination rights under the trading arrangement.