SEC Comment Letter for UNITED FIRE GROUP INC (UFCS) (CIK 0000101199) (UFCS) — Aug 17, 2005
UNITED FIRE GROUP INC (UFCS) (CIK 0000101199)
Date: Aug. 17, 2005 · CIK: 0000101199 · Accession: 0000000000-05-042439
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Via Facsimile and U.S. Mail
Mail Stop 6010
August 17, 2005
Mr. John A. Rife
President and Chief Executive Officer
United Fire & Casualty Company
118 Second Avenue SE
Cedar Rapids, Iowa 52407
Re: United Fire & Casualty Company
Form 10-K for Fiscal Year Ended December 31, 2004
Filed March 1, 2005
File No. 002-39621
Dear Mr. Rife:
We have limited our review of your filing to those issues we
have addressed in our comments. Where indicated, we think you
should
revise your document in response to these comments. If you
disagree,
we will consider your explanation as to why our comment is
inapplicable or a revision is unnecessary. Please be as detailed
as
necessary in your explanation.
Please understand that the purpose of our review process is
to
assist you in your compliance with the applicable disclosure
requirements and to enhance the overall disclosure in your filing.
We look forward to working with you in these respects. We welcome
any questions you may have about our comments or on any other
aspect
of our review. Feel free to call us at the telephone numbers
listed
at the end of this letter.
Item 7. Management`s Discussion and Analysis of Financial
Condition
and ..., page 10
Liquidity and Capital Resources, page 24
1. Please provide the disclosures required by Item 303(a)(5) of
Regulation S-K. In so doing, please include the expected
settlement
of the future policy benefits and losses, claims and settlement
expenses in the contractual obligation table. In this regard,
please
note that it would appear that these represent future legal
obligations of yours. Due to the apparently significant nature of
these liabilities to your business, we believe the inclusion of
these
liabilities in the contractual obligation table will provide
investors increased disclosure of your liquidity. The purpose of
Item 303(a)(5) and FR-67 appears to be to obtain enhanced
disclosure
concerning your contractual payment obligations and the exclusion
of
ordinary course items would appear to be inconsistent with that
purpose.
Critical Accounting Policies, page 25
Future Policy Benefits and Losses ... Property and Casualty
Insurance
Segment, page 26
2. It appears that your disclosure in Management`s Discussion and
Analysis regarding the reserve for loss, claims and settlement
expenses for your property and casualty insurance segment could be
improved to better explain the judgments and uncertainties
surrounding this estimate and the potential impact on your
financial
statements. It also appears that disclosures explaining the
likelihood that materially different amounts would be reported
under
different conditions or using different assumptions is consistent
with the objective of Management`s Discussion and Analysis.
Accordingly, please revise MD&A to include the following
information
for each of your lines of business.
* Please disclose the reserves accrued as of the latest balance
sheet
date presented. The total of theses amounts should agree to the
amount presented on the balance sheet.
* Please disclose the range of loss reserve estimates as
determined
by your actuaries. Discuss the key assumptions used to arrive at
management`s best estimate of loss reserves within that range and
what specific factors led management to believe this amount rather
than any other amount within the range represented the best
estimate
of incurred losses.
* If you do not calculate a range around your loss reserve, but
instead use point estimates please include the following
disclosures:
o Disclose the various methods considered and the method that was
selected to calculate the reserves. If multiple point estimates
are
generated, include the range of these point estimates. Include a
discussion of why the method selected was more appropriate over
the
other methods.
o Discuss how management determined the most appropriate point
estimate and why the other point estimates were not chosen. Also
clarify whether the company actually records to the point estimate
or
if not, how that estimate is used.
o Include quantified and narrative disclosure of the impact that
reasonably likely changes in one or more of the variables (i.e.
actuarially method and/or assumptions used) would have on reported
results, financial position and liquidity.
* Because IBNR reserve estimates are more imprecise, please
disclose
the amount of IBNR separately from case reserves for all lines of
business.
* For each line of your longer tail business with claims for
asbestos-related illnesses, environmental remediation, product
liability and other highly uncertain exposures, please provide
more
precise insight into the existence and effects on future
operations
and financial condition of known trends, events and uncertainties.
Disclosure you should consider, but not be limited to, includes
the
following information:
o the number of claims pending at each balance sheet date;
o the number of claims reported for each period presented;
o the number of claims dismissed, settled, or otherwise resolved
for
each period;
o the nature of the claims including relevant characteristics of
the
claimant population (e.g., involves a large number of relatively
small individual claims of a similar type);
o the total settlement amount for each period;
o the cost of administering the claims;
o emerging trends that may result in future reserve adjustments;
and
o if management is unable to estimate the possible loss or range
of
loss, a statement to that effect.
* * * *
As appropriate, please amend your Form 10-K for the year
ended
December 31, 2004 within 10 business days or tell us when you will
respond. You may wish to provide us with marked copies of the
amendment to expedite our review. Please furnish a cover letter
with
your amendment that keys your responses to our comments and
provides
any requested information. Detailed cover letters greatly
facilitate
our review. You should file the letter on EDGAR under the form
type
label CORRESP. Please understand that we may have additional
comments after reviewing your amendment and responses to our
comments.
We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filing to be certain that the
filing include all information required under the Securities
Exchange
Act of 1934 and that they have provided all information investors
require for an informed investment decision. Since the company
and
its management are in possession of all facts relating to a
company`s
disclosure, they are responsible for the accuracy and adequacy of
the
disclosures they have made.
In connection with responding to our comments, please
provide,
in your letter, a statement from the company acknowledging that:
* the company is responsible for the adequacy and accuracy of the
disclosure in the filings;
* staff comments or changes to disclosure in response to staff
comments do not foreclose the Commission from taking any action
with
respect to the filing; and
* the company may not assert staff comments as a defense in any
proceeding initiated by the Commission or any person under the
federal securities laws of the United States.
In addition, please be advised that the Division of
Enforcement
has access to all information you provide to the staff of the
Division of Corporation Finance in our review of your filing or in
response to our comments on your filing.
You may contact Ibolya Ignat, Staff Accountant at (202) 551-
3656, or Oscar M. Young, Senior Accountant at (202) 551-3622 if
you
have questions regarding the comments. In this regard, do not
hesitate to contact me, at (202) 551-3679.
Sincerely,
Jim B. Rosenberg
Senior Assistant Chief Accountant
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John A. Rife
United Fire & Casualty Company
August 17, 2005
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