SEC Company Response from SCOR (CIK 0001023027) — Jul 29, 2005
SCOR (CIK 0001023027)
Date: July 29, 2005 · CIK: 0001023027 · Accession: 0000950172-05-002395
AI Filing Summary & Sentiment
Referenced dates: July 25, 2005
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[SCOR letterhead]
Paris, July 29, 2005
Via Facsimile and EDGAR
Office of Corporate Finance
Securities and Exchange Commission
450 Fifth Street N.W.
Washington, D.C. 20549
U.S.A.
Attention: Jim B. Rosenberg
RE: Staff Comment Letter dated July 25, 2005 with respect to the
Form 20-F for the year ended December 31, 2004 of SCOR
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Dear Mr. Rosenberg,
I refer to the Staff's Comment Letter dated July 25, 2005 with respect to the
Form 20-F for the year ended December 31, 2004 of SCOR (the "Company").
The Company is currently in the process of reviewing the Staff's comments with
its actuarial and accounting teams (at the Company and at each of the Company
subsidiaries (the "Group")), as well as with its external counsel and
independent auditors.
While the Company has already begun to gather the necessary information in
order to respond to the Staff's comments, due to the nature of the information
required from the Group, the Company has determined that it will need at least
one month to gather and prepare, and approximately one month to analyze and
validate the information detailed below as part of the preparation of a
response to the Staff's comments.
o The Company must obtain detailed information notably
with respect to actuarial calculations and reserves
from each of its subsidiaries, and review and analyze
such information with the appropriate persons at each
of such subsidiaries;
o The Company must perform certain actuarial calculations
at the Group level, and construct the appropriate
models in order to perform such calculations ; and
o The Company will then need to properly prepare and
validate the answers to your questions.
The Company notes that its disclosures to the investing public are of utmost
importance to the Company, and the Company's corporate governance practices
reflect such importance. Accordingly, pursuant to the governing principles
(Reglement Interieur) of the Company's Board of Directors and Accounts and
Audit Committee, it is necessary for the Company's Accounts and Audit Committee
to give appropriate consideration to the Staff's comments and the Company's
responses to such comments prior to their submission to the Staff. Due to
factors beyond the Company's control, it is not possible to convene a meeting
of the Company's Accounts and Audit Committee prior to its next scheduled
meeting at the end of August. Therefore, it is unlikely that the Company's
Accounts and Audit Committee can give appropriate consideration to the matters
at hand prior to such time.
The Company notes the Staff's request that a response to its comments be filed
by the Company prior to August 8, 2005. However, in light of the foregoing, the
Company respectfully submits that it will be unable to file its response prior
to such date. The Company hereby respectfully submits to the Staff's
consideration the filing of its response to the Staff's comments prior to
September 30, 2005.
I would be happy to discuss any of the foregoing at your convenience, and can
be reached at 011-33-1-46-98-71-42.
I appreciate the Staff's assistance in this matter.
Sincerely,
/s/ Marcel Kahn
Marcel Kahn
Group Chief Financial Officer
cc: Securities and Exchange Commission
Joseph Roesler
Joel Parker
Skadden, Arps, Slate, Meagher & Flom LLP
Adrian Deitz
Armand Grumberg
Natalie Milani
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