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SEC Company Response from KINGSWAY FINANCIAL SERVICES INC (KFS) (CIK 0001072627) (KWY) — Jun 17, 2013

KINGSWAY FINANCIAL SERVICES INC (KFS) (CIK 0001072627)
Date: June 17, 2013 · CIK: 0001072627 · Accession: 0001072627-13-000064

AI Filing Summary & Sentiment

File numbers found in text: 333-188932

Date
June 17, 2013
Author
/s/ Brian J. Fahrney
Form
CORRESP
Company
KINGSWAY FINANCIAL SERVICES INC (KFS) (CIK 0001072627)

Letter

Correspondence 061713

June 17, 2013

Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, DC 20549

Attn: Jeffrey P. Riedler

Amy Reischauer

Daniel Greenspan

Re:

Kingsway Financial Services Inc.

Registration Statement on Form S-3

Filed May 30, 2013

File No. 333-188932

Ladies and Gentlemen:

This letter sets forth the response on behalf of Kingsway Financial Services Inc. (the “Company”) to your letter, dated June 7, 2013, setting forth the comment of the staff of the Division of Corporation Finance of the Securities and Exchange Commission (the “Commission”) on the Company's filing listed above. For your convenience, the comment is reproduced below before the Company's answers.

General

I.

Please provide your analysis in support of your position that you are eligible to use Form S-3 to register this offering. In your response, please address the analysis set forth in Question 116.20 of the Securities Act Forms Compliance and Disclosure Interpretations. Alternatively, please file a pre- effective amendment to your registration statement to convert it from S-3 to Form S-1.

Response: In response to the Staff's comment, the Company has filed a pre-effective amendment to Form S-3 on Form S-1, converting the aforementioned Registration Statement on Form S-3 to Form S-1.

Please feel free to call me with any questions at (312) 853-2066, or in my absence, my colleague Istvan Hajdu at (212) 839-5651.

Regards,
/s/ Brian J. Fahrney

Show Raw Text
CORRESP
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		Correspondence 061713

June 17, 2013

Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, DC 20549

Attn:   Jeffrey P. Riedler

           Amy Reischauer

           Daniel Greenspan

Re:

 Kingsway Financial Services Inc.

Registration Statement on Form S-3

Filed May 30, 2013

File No. 333-188932

Ladies and Gentlemen:

This letter sets forth the response on behalf of Kingsway Financial Services Inc. (the “Company”) to your letter, dated June 7, 2013, setting forth the comment of the staff of the Division of Corporation Finance of the Securities and Exchange Commission (the “Commission”) on the Company's filing listed above.  For your convenience, the comment is reproduced below before the Company's answers.

General

I.

 Please provide your analysis in support of your position that you are eligible to use Form S-3 to register this offering.  In your response, please address the analysis set forth in Question 116.20 of the Securities Act Forms Compliance and Disclosure Interpretations.  Alternatively, please file a pre- effective amendment to your registration statement to convert it from S-3 to Form S-1.

Response:  In response to the Staff's comment, the Company has filed a pre-effective amendment to Form S-3 on Form S-1, converting the aforementioned Registration Statement on Form S-3 to Form S-1.

Please feel free to call me with any questions at (312) 853-2066, or in my absence, my colleague Istvan Hajdu at (212) 839-5651.

Regards,

/s/ Brian J. Fahrney

Brian J. Fahrney