SEC Comment Letter 0000000000-24-000669 to UNITED FIRE GROUP INC (UFCS) (CIK 0000101199) (UFCS)
UNITED FIRE GROUP INC (UFCS) (CIK 0000101199)
Date: Jan. 18, 2024 · CIK: 0000101199 · Accession: 0000000000-24-000669
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File numbers found in text: 001-34257
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United States securities and exchange commission logo
January 18, 2024
Eric J. Martin
Chief Financial Officer
United Fire Group, Inc.
118 Second Avenue SE
Cedar Rapids, IA 52401
Re:United Fire Group, Inc.
Amendment No. 1 to Form 10-K for Fiscal Year Ended December 31, 2022
Form 8-K filed November 1, 2023
Response dated December 20, 2023
File No. 001-34257
Dear Eric J. Martin:
We have reviewed your December 20, 2023 response to our comment letter and have the
following comments.
Please respond to this letter 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 a
comment applies to your facts and circumstances, please tell us why in your response.
After reviewing your response to this letter, we may have additional comments. Unless
we note otherwise, any references to prior comments are to comments in our November 29,
2023 letter.
Amendment No. 1 to Form 10-K for Fiscal Year Ended December 31, 2022
Item 7. Management's Discussion and Analysis of Financial Condition and Results of Operations
Financial Highlights, page 32
1.We note your response to prior comment 1. Your presentation of net underlying loss ratio
represents a non-GAAP financial measure given that it excludes amounts that are included
in the net loss ratio, the most directly comparable measure calculated and presented in
accordance with GAAP. Please revise your future filings to clearly label and identify your
net underlying loss ratio as a non-GAAP financial measure and provide all of the relevant
disclosures required by Item 10(e)(1) of Regulation S-K.
FirstName LastNameEric J. Martin
Comapany NameUnited Fire Group, Inc.
January 18, 2024 Page 2
FirstName LastName
Eric J. Martin
United Fire Group, Inc.
January 18, 2024
Page 2
Form 8-K filed November 1, 2023
Certain Performance Measures, page 7
2.We note your response to prior comment 3. Your presentations of net underlying loss ratio
and underlying combined ratio represent non-GAAP financial measures given that they
exclude amounts that are included in the net loss ratio and combined ratio, the most
directly comparable measures calculated and presented in accordance with GAAP. Please
revise your future filings to clearly label and identify your net underlying loss ratio and
underlying combined ratio as non-GAAP financial measures and provide all of the
relevant disclosures required by Item 10(e)(1) of Regulation S-K.
Please contact Katharine Garrett at 202-551-2332 or William Schroeder at 202-551-3294
if you have questions regarding comments on the financial statements and related matters.
Sincerely,
Division of Corporation Finance
Office of Finance