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SEC Comment Letter for STANDARD MANAGEMENT CORP (CIK 0000853971) — Sep 9, 2005

STANDARD MANAGEMENT CORP (CIK 0000853971)
Date: Sept. 9, 2005 · CIK: 0000853971 · Accession: 0000000000-05-046707

AI Filing Summary & Sentiment

Date
September 9, 2005
Author
Jeffrey P. Riedler
Form
UPLOAD
Company
STANDARD MANAGEMENT CORP (CIK 0000853971)

Letter

Mail Stop 6010 September 9, 2005 Ronald D. Hunter Chief Executive Officer and President Standard Management Corporation 10689 North Pennsylvania Indianapolis, Indiana 46280

Re: Standard Management Corporation Preliminary Proxy Statement on Schedule 14A, Filed September 2, File No. 0-20882

Dear Mr. Hunter:

This is to advise you that we have limited our review of the above referenced proxy statement to only the issues identified below.

Schedule 14A 1. Please revise your proxy statement to include a brief discussion on the reasons the company engaged in the private placement issuance. In addition, please discuss the specific use of proceeds from the private placement issuance. 2. Please also revise your proxy statement to include a brief discussion on the dilutive impact that the private placement has had or will have on your shareholders. To the extent possible, please quantify your disclosure.

* * *

You may wish to provide us with marked copies of the amendment to expedite our review. Please furnish a response letter with your amendment that keys your responses to our comments. Detailed cover letters greatly facilitate our review. Please file your cover 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.

Please contact Song P. Brandon at (202) 551-3621 with any other questions.

Sincerely,
Jeffrey P. Riedler
Assistant Director
??

Show Raw Text
<DOCUMENT>
<TYPE>LETTER
<SEQUENCE>1
<FILENAME>filename1.txt
<TEXT>

Mail Stop 6010

      September 9, 2005

Ronald D. Hunter
Chief Executive Officer and President
Standard Management Corporation
10689 North Pennsylvania
Indianapolis, Indiana  46280

Re:  	Standard Management Corporation
	Preliminary Proxy Statement on Schedule 14A, Filed September
2,
2005
	File No. 0-20882

Dear Mr. Hunter:

      This is to advise you that we have limited our review of the
above referenced proxy statement to only the issues identified
below.

Schedule 14A
1. Please revise your proxy statement to include a brief
discussion
on the reasons the company engaged in the private placement
issuance.
In addition, please discuss the specific use of proceeds from the
private placement issuance.
2. Please also revise your proxy statement to include a brief
discussion on the dilutive impact that the private placement has
had
or will have on your shareholders.  To the extent possible, please
quantify your disclosure.

*	*	*

      You may wish to provide us with marked copies of the
amendment
to expedite our review.  Please furnish a response letter with
your
amendment that keys your responses to our comments.  Detailed
cover
letters greatly facilitate our review.  Please file your cover
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.

      Please contact Song P. Brandon at (202) 551-3621 with any
other
questions.

								Sincerely,

								Jeffrey P. Riedler
								Assistant Director
??

??

??

??

</TEXT>
</DOCUMENT>