SEC Company Response from ASPEN INSURANCE HOLDINGS LTD (AHL, AHL-PD, AHL-PE, AHL-PF) (CIK 0001267395) (AHL-PD) — Jan 28, 2005
ASPEN INSURANCE HOLDINGS LTD (AHL, AHL-PD, AHL-PE, AHL-PF) (CIK 0001267395)
Date: Jan. 28, 2005 · CIK: 0001267395 · Accession: 0000950136-05-000427
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 333-122018
Referenced dates: January 24, 2005
Letter
VIA FASCIMILE AND EDGAR --------------------------------- Mr. Jeffrey P. Riedler Assistant Director Division of Corporation Finance United States Securities and Exchange Commission 450 Fifth Street, N.W. Washington, D.C. 20549
RE: ASPEN INSURANCE HOLDINGS LIMITED REGISTRATION STATEMENT ON FORM F-4, FILED JANUARY 13, 2005 REGISTRATION NO. 333-122018
Dear Mr. Riedler:
On behalf of Aspen Insurance Holdings Limited (the "Company"), we would like to respond to the Comment No. 1 of the Staff of the Division of Corporation Finance of the Commission, set forth in your letter dated January 24, 2005 to the Company, with respect to the above-referenced Registration Statement (the "Registration Statement").
For your convenience, we set forth in bold typeface the relevant portions of Comment No. 1 from your letter and include the Company's response below such comment.
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1. IT APPEARS YOU ARE REGISTERING THE EXCHANGE NOTES IN RELIANCE ON THE STAFF'S POSITION SET FORTH IN EXXON CAPITAL HOLDINGS CORPORATION (MAY 13, 1988), MORGAN STANLEY & CO. INCORPORATED (JUNE 5, 1991), AND SHERMAN & STERLING (JULY 2, 1993). ACCORDINGLY, PLEASE PROVIDE US WITH A SUPPLEMENTAL LETTER CONTAINING THE STATEMENTS AND REPRESENTATIONS THAT ARE SET FORTH IN THOSE LETTERS.
The Company submitted as correspondence through the EDGAR system on January 18, 2005 a supplemental letter which contains the statements and the representations referred to in Exxon Capital Holdings Corporation (May 13, 1988), Morgan Stanley & Co. Incorporated (June 5, 1991), and Sherman & Sterling (July 2, 1993). A copy of such supplemental letter relating to the Registration Statement is attached hereto for your reference.
----------------------
Thank you for your consideration. If you have any further questions or comments, please contact me at (011-44) 207-459-5125 or Michael Groll at (212) 424-8616.
Sincerely,
/s/ Joseph Ferraro
Show Raw Text
CORRESP
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LEBOEUF, LAMB, GREENE & MACRAE
L.L.P.
A LIMITED LIABILITY PARTNERSHIP INCLUDING PROFESSIONAL CORPORATIONS
NEW YORK LONDON
WASHINGTON, D.C. A MULTINATIONAL PARTNERSHIP (A LONDON-BASED
ALBANY 1 MINSTER COURT MULTINATIONAL PARTNERSHIP
BOSTON PARIS
HARRISBURG MINCING LANE BRUSSELS
HARTFORD JOHANNESBURG
HOUSTON LONDON, EC3R 7YL, ENGLAND (PTY) LTD.
JACKSONVILLE 011 44 20 7459 5000 MOSCOW
LOS ANGELES FACSIMILE: 011 44 20 7459 5099 RIYADH
NEWARK (AFFILIATED OFFICE)
PITTSBURGH BISHKEK
SALT LAKE CITY ALMATY
SAN FRANCISCO BEIJING
January 28, 2005
VIA FASCIMILE AND EDGAR
---------------------------------
Mr. Jeffrey P. Riedler
Assistant Director
Division of Corporation Finance
United States Securities and Exchange Commission
450 Fifth Street, N.W.
Washington, D.C. 20549
RE: ASPEN INSURANCE HOLDINGS LIMITED
REGISTRATION STATEMENT ON FORM F-4,
FILED JANUARY 13, 2005
REGISTRATION NO. 333-122018
Dear Mr. Riedler:
On behalf of Aspen Insurance Holdings Limited (the "Company"),
we would like to respond to the Comment No. 1 of the Staff of the Division of
Corporation Finance of the Commission, set forth in your letter dated January
24, 2005 to the Company, with respect to the above-referenced Registration
Statement (the "Registration Statement").
For your convenience, we set forth in bold typeface the
relevant portions of Comment No. 1 from your letter and include the Company's
response below such comment.
----------------------
1. IT APPEARS YOU ARE REGISTERING THE EXCHANGE NOTES IN RELIANCE ON THE
STAFF'S POSITION SET FORTH IN EXXON CAPITAL HOLDINGS CORPORATION (MAY
13, 1988), MORGAN STANLEY & CO. INCORPORATED (JUNE 5, 1991), AND
SHERMAN & STERLING (JULY 2, 1993). ACCORDINGLY, PLEASE PROVIDE US WITH
A SUPPLEMENTAL LETTER CONTAINING THE STATEMENTS AND REPRESENTATIONS
THAT ARE SET FORTH IN THOSE LETTERS.
The Company submitted as correspondence through the EDGAR system on January
18, 2005 a supplemental letter which contains the statements and the
representations referred to in Exxon Capital Holdings Corporation (May 13,
1988), Morgan Stanley & Co. Incorporated (June 5, 1991), and Sherman &
Sterling (July 2, 1993). A copy of such supplemental letter relating to the
Registration Statement is attached hereto for your reference.
----------------------
Thank you for your consideration. If you have any further
questions or comments, please contact me at (011-44) 207-459-5125 or
Michael Groll at (212) 424-8616.
Sincerely,
/s/ Joseph Ferraro
Joseph Ferraro
cc: Albert Lee
United States Securities and Exchange Commission
Julian Cusack
David Curtin
Aspen Insurance Holdings Limited
Michael Groll
LeBoeuf, Lamb, Greene & MacRae, L.L.P.