SEC Comment Letter 0000000000-24-010131 to HORACE MANN EDUCATORS CORP /DE/ (HMN) (CIK 0000850141) (HMN)
HORACE MANN EDUCATORS CORP /DE/ (HMN) (CIK 0000850141)
Date: Sept. 6, 2024 · CIK: 0000850141 · Accession: 0000000000-24-010131
AI Filing Summary & Sentiment
File numbers found in text: 001-10890
Letter
September 6, 2024 Bret A. Conklin Executive Vice President and Chief Financial Officer Horace Mann Educators Corporation 1 Horace Mann Plaza Springfield, IL 62715-0001 Re:Horace Mann Educators Corporation Form 10-K For the Fiscal Year Ended December 31, 2023 File No. 001-10890 Dear Bret A. Conklin: We have limited our review of your filing to the financial statements and related disclosures 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. Form 10-K For the Fiscal Year Ended December 31, 2023 Consolidated Statements of Operations and Comprehensive Income (Loss), page 73 1.Please represent to us that, in future filings, you will revise your presentation to provide either the separate line item or parenthetical disclosure associated with the various remeasurement gains/losses as stipulated in ASC 944-40-45-1, 45-2 and 45-4. Notes to Consolidated Financial Statements Note 1 - Basis of Presentation and Significant Accounting Policies Short-Duration Insurance Contracts, page 84 2.Please represent to us that, in future filings, you will revise your policy note to disclose your policy for premium deficiency testing and specifically indicate whether you consider anticipated investment income in the test as required by ASC 944-60-50-1. Otherwise tell us where you made this disclosure in your financial statements.
September 6, 2024 Page 2 Note 6 - Long-Duration Insurance Contracts Liability for Future Policy Benefits, page 117 3.We note from your gross premiums or assessments table on page 121 that in 2023 and 2022 the supplemental health line represents approximately half of your premium/assessment revenue depicted in the table and in your rollforwards of the liability for future policy benefits and, in each case, over 40% of premiums and contract charges earned in the Supplemental & Group Benefits segment. Please represent to us that, in future filings, in addition to the mortality and lapse actual versus expected experience information provided on page 122 for your life products, you will provide the actual versus expected morbidity and lapse experience information for your supplemental health products as required by ASC 944-40-50-6b2. In closing, 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 Bonnie Baynes at 202-551-4924 or Mark Brunhofer at 202-551-3638 with any questions. Sincerely, Division of Corporation Finance Office of Crypto Assets cc:Donald Carley
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September 6, 2024
Bret A. Conklin
Executive Vice President and Chief Financial Officer
Horace Mann Educators Corporation
1 Horace Mann Plaza
Springfield, IL 62715-0001
Re:Horace Mann Educators Corporation
Form 10-K For the Fiscal Year Ended December 31, 2023
File No. 001-10890
Dear Bret A. Conklin:
We have limited our review of your filing to the financial statements and related
disclosures 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.
Form 10-K For the Fiscal Year Ended December 31, 2023
Consolidated Statements of Operations and Comprehensive Income (Loss), page 73
1.Please represent to us that, in future filings, you will revise your presentation to provide
either the separate line item or parenthetical disclosure associated with the various
remeasurement gains/losses as stipulated in ASC 944-40-45-1, 45-2 and 45-4.
Notes to Consolidated Financial Statements
Note 1 - Basis of Presentation and Significant Accounting Policies
Short-Duration Insurance Contracts, page 84
2.Please represent to us that, in future filings, you will revise your policy note to disclose
your policy for premium deficiency testing and specifically indicate whether you consider
anticipated investment income in the test as required by ASC 944-60-50-1. Otherwise tell
us where you made this disclosure in your financial statements.
September 6, 2024
Page 2
Note 6 - Long-Duration Insurance Contracts
Liability for Future Policy Benefits, page 117
3.We note from your gross premiums or assessments table on page 121 that in 2023 and
2022 the supplemental health line represents approximately half of your
premium/assessment revenue depicted in the table and in your rollforwards of the liability
for future policy benefits and, in each case, over 40% of premiums and contract charges
earned in the Supplemental & Group Benefits segment. Please represent to us that, in
future filings, in addition to the mortality and lapse actual versus expected
experience information provided on page 122 for your life products, you will provide the
actual versus expected morbidity and lapse experience information for your supplemental
health products as required by ASC 944-40-50-6b2.
In closing, 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 Bonnie Baynes at 202-551-4924 or Mark Brunhofer at 202-551-3638 with
any questions.
Sincerely,
Division of Corporation Finance
Office of Crypto Assets
cc:Donald Carley