SEC Comment Letter for ASPEN INSURANCE HOLDINGS LTD (AHL, AHL-PD, AHL-PE, AHL-PF) (CIK 0001267395) (AHL-PD) — Dec 15, 2011
ASPEN INSURANCE HOLDINGS LTD (AHL, AHL-PD, AHL-PE, AHL-PF) (CIK 0001267395)
Date: Dec. 15, 2011 · CIK: 0001267395 · Accession: 0000000000-11-071851
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 001-31909
Letter
Re: Aspen Insurance Holdings Limited Form 10-K for the Fiscal Year Ended December 31, 2010 Filed February 25, 2011 File No. 001-31909 Dear Mr. O’Kane:
December 15, 2011
Via E-mail Mr. Christopher O’Kane Chief Executive Officer Aspen Insurance Holdings Limited 141 Front Street Hamilton, Bermuda HM19
We have limited our review to only your fi nancial statements and related disclosures and do not intend to expand our review to ot her portions of your document. In our comments, we ask you to provide us with in formation so we may better understand your disclosure.
Please respond to this letter within 10 business days by providing the requested information or by advising us when you will provide the requested response. If you do not believe a comment applies to your facts a nd circumstances, please tell us why in your response. Please furnish us a letter on EDGA R under the form type label CORRESP that keys your responses to our comments.
After reviewing the information provided, we may raise additional comments and/or request that you amend your filing.
Management’s Discussion and Analysis of Fi nancial Condition and Results of Operations
Valuation of Investments, page 123
1. You disclose in the table on page 124 th at index providers re presented 85.2% and 81.4% of the pricing sources for your fi xed-income investments in 2010 and 2009. You also disclose that your index service providers have the highest priority in your price source hierarchy. Please tell us: What information the index service providers provided you; The specific investments for which the information was used; How the information was used to determine fair value of the investments; and The processes used by management to determine that the information provided by index providers wa s appropriate.
Mr. Christopher O’Kane Aspen Insurance Holdings Limited December 15, 2011 Page 2
Consolidated Financial Statements
Notes to Consolidated Financial Statements Note 19 – Concentrations of Credit Risk, page F-53
2. You entered into interest rate swaps with a total notional amount of $500.0 million at December 31, 2010 and $1 billion at September 30, 2011 that mature between August 2, 2012 and November 9, 2020 to hedge your investment portfolio against increases in interest rates . In the event that a ny counterparties fail to meet their contractual obligations under these swaps, it appears you would be exposed to counterparty credit risks. Please provide us with the following information: The names of the significant counterpart ies for your interest rate swaps; The notional amounts and amounts due fr om each of these counterparties; The processes and procedures you undertak e to assess the financial strength and ability of the counterparties to perform on their obligations; The nature of the non-cash collateral r eceived from the swap counterparty at December 31, 2010 and how you determine the value of the non-cash collateral; and The maximum amount of loss due to credit ri sk if the counterparties were to fail.
We urge all persons who are responsible for the accuracy and adequacy of the disclosure in the filing to be certain that the filing includes the information the Securities Exchange Act of 1934 and all applicable Exchan ge Act rules require. Since the company and its management are in possession of all facts relating to a co mpany’s disclosure, they are responsible for the accuracy and adequacy of the disclosures they have made. In responding to our comments, please pr ovide a written statement from the company acknowledging that: the company is responsible for the adequacy and accuracy of the disclosure in the filing; staff comments or changes to disclosure in response to staff comments do not foreclose the Commission from taking any action with respect to the filing; and the company may not assert staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.
You may contact Don Abbott, Staff A ccountant, at (202) 551-3608, or Gus Rodriguez, Accounting Branch Chief, at (202) 551-3752 if you have any questions regarding the comments. In this regard, do not he sitate to contact me at (202) 551-3679.
Sincerely,
/ s / J i m B . R o s e n b e r g
Show Raw Text
December 15, 2011
Via E-mail
Mr. Christopher O’Kane
Chief Executive Officer
Aspen Insurance Holdings Limited
141 Front Street
Hamilton, Bermuda HM19
Re: Aspen Insurance Holdings Limited
Form 10-K for the Fiscal Year Ended December 31, 2010
Filed February 25, 2011
File No. 001-31909
Dear Mr. O’Kane:
We have limited our review to only your fi nancial statements and related disclosures
and do not intend to expand our review to ot her portions of your document. In our
comments, we ask you to provide us with in formation so we may better understand your
disclosure.
Please respond to this letter within 10 business days by providing the requested
information or by advising us when you will provide the requested response. If you do not believe a comment applies to your facts a nd circumstances, please tell us why in your
response. Please furnish us a letter on EDGA R under the form type label CORRESP that
keys your responses to our comments.
After reviewing the information provided, we may raise additional comments and/or
request that you amend your filing.
Management’s Discussion and Analysis of Fi nancial Condition and Results of Operations
Valuation of Investments, page 123
1. You disclose in the table on page 124 th at index providers re presented 85.2% and
81.4% of the pricing sources for your fi xed-income investments in 2010 and 2009.
You also disclose that your index service providers have the highest priority in your
price source hierarchy. Please tell us:
What information the index service providers provided you;
The specific investments for which the information was used;
How the information was used to determine fair value of the investments; and
The processes used by management to determine that the information provided by
index providers wa s appropriate.
Mr. Christopher O’Kane
Aspen Insurance Holdings Limited December 15, 2011 Page 2
Consolidated Financial Statements
Notes to Consolidated Financial Statements
Note 19 – Concentrations of Credit Risk, page F-53
2. You entered into interest rate swaps with a total notional amount of $500.0 million at
December 31, 2010 and $1 billion at September 30, 2011 that mature between August 2,
2012 and November 9, 2020 to hedge your investment portfolio against increases in
interest rates . In the event that a ny counterparties fail to meet their contractual
obligations under these swaps, it appears you would be exposed to counterparty credit
risks. Please provide us with the following information:
The names of the significant counterpart ies for your interest rate swaps;
The notional amounts and amounts due fr om each of these counterparties;
The processes and procedures you undertak e to assess the financial strength and
ability of the counterparties to perform on their obligations;
The nature of the non-cash collateral r eceived from the swap counterparty at
December 31, 2010 and how you determine the value of the non-cash collateral;
and
The maximum amount of loss due to credit ri sk if the counterparties were to fail.
We urge all persons who are responsible for the accuracy and adequacy of the
disclosure in the filing to be certain that the filing includes the information the Securities
Exchange Act of 1934 and all applicable Exchan ge Act rules require. Since the company and
its management are in possession of all facts relating to a co mpany’s disclosure, they are
responsible for the accuracy and adequacy of the disclosures they have made.
In responding to our comments, please pr ovide a written statement from the company
acknowledging that:
the company is responsible for the adequacy and accuracy of the disclosure in the
filing;
staff comments or changes to disclosure in response to staff comments do not
foreclose the Commission from taking any action with respect to the filing; and
the company may not assert staff comments as a defense in any proceeding initiated
by the Commission or any person under the federal securities laws of the United
States.
You may contact Don Abbott, Staff A ccountant, at (202) 551-3608, or Gus
Rodriguez, Accounting Branch Chief, at (202) 551-3752 if you have any questions regarding
the comments. In this regard, do not he sitate to contact me at (202) 551-3679.
Sincerely,
/ s / J i m B . R o s e n b e r g
Jim B. Rosenberg
Senior Assistant Chief Accountant