SEC Comment Letter for ASPEN INSURANCE HOLDINGS LTD (AHL, AHL-PD, AHL-PE, AHL-PF) (CIK 0001267395) (AHL-PD) — Dec 6, 2013
ASPEN INSURANCE HOLDINGS LTD (AHL, AHL-PD, AHL-PE, AHL-PF) (CIK 0001267395)
Date: Dec. 6, 2013 · CIK: 0001267395 · Accession: 0000000000-13-066738
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 001-31909
Letter
December 6 , 2013 Via E-mail Mr. John Worth Chief Financial Officer Aspen Insurance Holding Limited 141 Front Street Hamilton, Bermuda HM 19
Re: Aspen Insurance Holding Limited Form 10-K for the Year Ended December 31 , 2012 Filed February 26, 201 3 File No. 001-31909
Dear M r. Worth :
We have reviewed your November 5, 2013 response to our October 31, 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 re sponse. 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 EDGAR under the form type label CORRESP that key s your response to our comment .
After reviewing the information you provide, we may have additional comments and/or request that you amend your filing.
Notes to the Audited Consolidated Financial Statements Note 11. Income Taxes, page F -42
1. We acknowledge your response to our comment 2. Please address the following additional comments: Please tell us more about your significant prior year adjustments relative to expected tax benefit/exp ense in 2012 and 2010 and explain to us why these adjustments are not indicative of errors in prior year financial statements. Please tell us why you were not able to make more accurate estimates in your initial provision estimates including what addition al information was learned after the completion of your previous financial statements and before the filings of your tax returns. Please provide us a proposed revised rate reconciliation table and associated clarifying disclosure to be included in future p eriodic reports that separately describes each reconciling item over 5% of the expected income tax benefit or expense.
Mr. John Worth Aspen Insurance Holding Limited December 6 , 2013 Page 2
You may contact Sasha Parikh, Staff Accountant, at (202) 551 -3627 or Mark Brunhofer , Revi ew Accountant, at (202) 551 -3638 if you have questions regarding the comment . In this regard, do not hesitate to contact me at (202) 551 -3679.
Sincerely,
/s/ Jim B . Rosenberg
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December 6 , 2013 Via E-mail Mr. John Worth Chief Financial Officer Aspen Insurance Holding Limited 141 Front Street Hamilton, Bermuda HM 19 Re: Aspen Insurance Holding Limited Form 10-K for the Year Ended December 31 , 2012 Filed February 26, 201 3 File No. 001-31909 Dear M r. Worth : We have reviewed your November 5, 2013 response to our October 31, 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 re sponse. 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 EDGAR under the form type label CORRESP that key s your response to our comment . After reviewing the information you provide, we may have additional comments and/or request that you amend your filing. Notes to the Audited Consolidated Financial Statements Note 11. Income Taxes, page F -42 1. We acknowledge your response to our comment 2. Please address the following additional comments: Please tell us more about your significant prior year adjustments relative to expected tax benefit/exp ense in 2012 and 2010 and explain to us why these adjustments are not indicative of errors in prior year financial statements. Please tell us why you were not able to make more accurate estimates in your initial provision estimates including what addition al information was learned after the completion of your previous financial statements and before the filings of your tax returns. Please provide us a proposed revised rate reconciliation table and associated clarifying disclosure to be included in future p eriodic reports that separately describes each reconciling item over 5% of the expected income tax benefit or expense. Mr. John Worth Aspen Insurance Holding Limited December 6 , 2013 Page 2 You may contact Sasha Parikh, Staff Accountant, at (202) 551 -3627 or Mark Brunhofer , Revi ew Accountant, at (202) 551 -3638 if you have questions regarding the 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