SEC Comment Letter for KINGSWAY FINANCIAL SERVICES INC (KFS) (CIK 0001072627) (KWY) — Oct 25, 2013
KINGSWAY FINANCIAL SERVICES INC (KFS) (CIK 0001072627)
Date: Oct. 25, 2013 · CIK: 0001072627 · Accession: 0000000000-13-058891
AI Filing Summary & Sentiment
File numbers found in text: 001-15204
Letter
October 25 , 2013 Via E-mail Mr. Larry G. Swets, Jr. President and Chief Executive Officer Kingsway Financial Services, Inc. 45 St. Clair Avenue West, Suite 400 Toronto, Ontario, Canada M4V 1K9
Re: Kingsway Financial Services , Inc. Form 10-K for Fiscal Year Ended December 31, 201 2 Filed March 22 , 2013 File No. 001-15204
Dear Mr. Swets :
We have reviewed your September 30, 2013 response to our September 17 , 2013 letter and have the following comment .
Please respond to this letter within 10 business days by providing the requested information or by advising us when you will provide the requested r esponse. If you do not believe the comment applies to your facts and cir cumstances, please tell us why in your response. Please furnish us a letter on EDGAR under the form type label CORRESP that keys your response to our comment .
After reviewing the information provided, we may raise additional comments and/or request that you amend your filing.
Notes to Consolidated Financial Statements Note 11 Intangible Assets, page 69
1. Please refer to prior comment 1. Please provide the information in your response as proposed disclosure to be included in future periodic filings, part icularly your basis for concluding that the renewal rights have an indefinite useful life. Also, explain to us your basis for using undiscounted cash flows in evaluating impairment of this non -amortizing intangible asset, particularly your consideration of ASC 350 -30-35-18.
Mr. Larry G. Swets, Jr. Kingsway Financial Services, Inc. October 25 , 201 3 Page 2
Please contact Frank Wyman, Staff Accountant, at (202) 551 -3660 or Mark Brunhofer , Senior Staff Accountant , at (202) 551 -3638, if you have any questions regarding th e comment. In this regard, do not hesitate to contact me at (202) 551-3679.
Sincerely,
/s/ Jim B. Rosenberg
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October 25 , 2013 Via E-mail Mr. Larry G. Swets, Jr. President and Chief Executive Officer Kingsway Financial Services, Inc. 45 St. Clair Avenue West, Suite 400 Toronto, Ontario, Canada M4V 1K9 Re: Kingsway Financial Services , Inc. Form 10-K for Fiscal Year Ended December 31, 201 2 Filed March 22 , 2013 File No. 001-15204 Dear Mr. Swets : We have reviewed your September 30, 2013 response to our September 17 , 2013 letter and have the following comment . Please respond to this letter within 10 business days by providing the requested information or by advising us when you will provide the requested r esponse. If you do not believe the comment applies to your facts and cir cumstances, please tell us why in your response. Please furnish us a letter on EDGAR under the form type label CORRESP that keys your response to our comment . After reviewing the information provided, we may raise additional comments and/or request that you amend your filing. Notes to Consolidated Financial Statements Note 11 Intangible Assets, page 69 1. Please refer to prior comment 1. Please provide the information in your response as proposed disclosure to be included in future periodic filings, part icularly your basis for concluding that the renewal rights have an indefinite useful life. Also, explain to us your basis for using undiscounted cash flows in evaluating impairment of this non -amortizing intangible asset, particularly your consideration of ASC 350 -30-35-18. Mr. Larry G. Swets, Jr. Kingsway Financial Services, Inc. October 25 , 201 3 Page 2 Please contact Frank Wyman, Staff Accountant, at (202) 551 -3660 or Mark Brunhofer , Senior Staff Accountant , at (202) 551 -3638, if you have any questions regarding th e comment. In this regard, do not hesitate to contact me at (202) 551-3679. Sincerely, /s/ Jim B. Rosenberg Jim B. Rosenberg Senior Assistant Chief Accountant