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
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<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
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