SEC Comment Letter for ASPEN INSURANCE HOLDINGS LTD (AHL, AHL-PD, AHL-PE, AHL-PF) (CIK 0001267395) (AHL-PD) — Jan 23, 2012
ASPEN INSURANCE HOLDINGS LTD (AHL, AHL-PD, AHL-PE, AHL-PF) (CIK 0001267395)
Date: Jan. 23, 2012 · CIK: 0001267395 · Accession: 0000000000-12-003680
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:
January 23, 2012
Via E-mail Mr. Christopher O’Kane Chief Executive Officer Aspen Insurance Holdings Limited 141 Front Street Hamilton, Bermuda HM19
We have reviewed your January 9, 2012 re sponse to our December 15, 2011letter 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 response. If you do not believe the comment applies to your facts and 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 response to our comment. 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. Please expand your proposed disclosure to discuss the differences in valuation approaches between a pricing service and an index service provider. Disclose if an index is one of the various market conven tions used by an index service provider and if so disclose how an index is used to de termine a price for an individual security.
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 comment. 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
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January 23, 2012
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 reviewed your January 9, 2012 re sponse to our December 15, 2011letter 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 response. If you do not believe the comment applies to your facts and 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 response to our comment.
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. Please expand your proposed disclosure to discuss the differences in valuation
approaches between a pricing service and an index service provider. Disclose if an
index is one of the various market conven tions used by an index service provider and
if so disclose how an index is used to de termine a price for an individual security.
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 comment. 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