SecProbe.io

Filing text and metadata
Intelligence Terminal Search Probe Scores Topics IPO Watchlist Monthly Activity About API

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

Date
July 29, 2005
Author
/s/ Marcel Kahn
Form
CORRESP
Company
SCOR (CIK 0001023027)

Letter

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 ------------------------------------------------------------

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

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

                               [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
              ------------------------------------------------------------

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

</TEXT>
</DOCUMENT>