SEC Comment Letter 0000000000-24-004446 to ASPEN INSURANCE HOLDINGS LTD (AHL, AHL-PD, AHL-PE, AHL-PF) (CIK 0001267395) (AHL)
ASPEN INSURANCE HOLDINGS LTD (AHL, AHL-PD, AHL-PE, AHL-PF) (CIK 0001267395)
Date: April 23, 2024 · CIK: 0001267395 · Accession: 0000000000-24-004446
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 333-276163
Referenced dates: January 12, 2024
Letter
United States securities and exchange commission logo April 23, 2024 Mark Cloutier Chief Executive Officer Aspen Insurance Holdings Limited 141 Front Street Hamilton, HM19 Bermuda Re:Aspen Insurance Holdings Limited Amendment No. 2 to Registration Statement on Form F-1 Filed April 5, 2024 File No. 333-276163 Dear Mark Cloutier: We have reviewed your amended registration statement and have the following comments. Please respond to this letter by amending your registration statement and providing the requested information. If you do not believe a comment applies to your facts and circumstances or do not believe an amendment is appropriate, please tell us why in your response. After reviewing any amendment to your registration statement and the information you provide in response to this letter, we may have additional comments. Unless we note otherwise, any references to prior comments are to comments in our February 20, 2024 letter. Amendment No. 2 to Registration Statement on Form F-1 General 1.We note your response to prior comment 1 and the presentation on pages 7 and 11 of upper single digit CAGR for overall and insurance-segment gross written premiums. This presentation includes quantitative disclosure of the positive results in each year for 5 years except for 2023, which had negative 7.7% and 2.3% returns, respectively. Please revise Item 5 to further clarify in qualitative terms the reasons for these trends, especially the change to negative CAGR in 2023, and include a cross reference to Item 5 from the discussion of CAGR in the Summary.
FirstName LastNameMark Cloutier Comapany NameAspen Insurance Holdings Limited April 23, 2024 Page 2 FirstName LastName Mark Cloutier Aspen Insurance Holdings Limited April 23, 2024 Page 2 Exhibits 2.We note there are multiple exhibits marked "to be filed." We also note your response to prior comment 14 of our letter dated January 12, 2024. Please provide a legal analysis as to why you believe, if true, that the investment management agreement described on pages 24 and F-63 is not required to be filed as an exhibit under Item 601(b)(10) of Regulation S-K. Please contact John Stickel at 202-551-3324 or James Lopez at 202-551-3536 with any other questions. Sincerely, Division of Corporation Finance Office of Finance cc: Robert A. Ryan, Esq.
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United States securities and exchange commission logo
April 23, 2024
Mark Cloutier
Chief Executive Officer
Aspen Insurance Holdings Limited
141 Front Street
Hamilton, HM19
Bermuda
Re:Aspen Insurance Holdings Limited
Amendment No. 2 to Registration Statement on Form F-1
Filed April 5, 2024
File No. 333-276163
Dear Mark Cloutier:
We have reviewed your amended registration statement and have the following
comments.
Please respond to this letter by amending your registration statement and providing the
requested information. If you do not believe a comment applies to your facts and circumstances
or do not believe an amendment is appropriate, please tell us why in your response.
After reviewing any amendment to your registration statement and the information you
provide in response to this letter, we may have additional comments. Unless we note otherwise,
any references to prior comments are to comments in our February 20, 2024 letter.
Amendment No. 2 to Registration Statement on Form F-1
General
1.We note your response to prior comment 1 and the presentation on pages 7 and 11 of
upper single digit CAGR for overall and insurance-segment gross written premiums. This
presentation includes quantitative disclosure of the positive results in each year for 5 years
except for 2023, which had negative 7.7% and 2.3% returns, respectively. Please revise
Item 5 to further clarify in qualitative terms the reasons for these trends, especially the
change to negative CAGR in 2023, and include a cross reference to Item 5 from the
discussion of CAGR in the Summary.
FirstName LastNameMark Cloutier
Comapany NameAspen Insurance Holdings Limited
April 23, 2024 Page 2
FirstName LastName
Mark Cloutier
Aspen Insurance Holdings Limited
April 23, 2024
Page 2
Exhibits
2.We note there are multiple exhibits marked "to be filed." We also note your response to
prior comment 14 of our letter dated January 12, 2024. Please provide a legal analysis as
to why you believe, if true, that the investment management agreement described on pages
24 and F-63 is not required to be filed as an exhibit under Item 601(b)(10) of Regulation
S-K.
Please contact John Stickel at 202-551-3324 or James Lopez at 202-551-3536 with any
other questions.
Sincerely,
Division of Corporation Finance
Office of Finance
cc: Robert A. Ryan, Esq.