SEC Comment Letter for National Interstate CORP (CIK 0001301106) — Jan 6, 2005
National Interstate CORP (CIK 0001301106)
Date: Jan. 6, 2005 · CIK: 0001301106 · Accession: 0000000000-05-001107
AI Filing Summary & Sentiment
File numbers found in text: 333-119270
Letter
Mail Stop 3-09 January 6, 2005 Michael Schroeder Vice President, Secretary and General Counsel National Interstate Corporation 3250 Interstate Drive Richfield, OH 44286-9000
Re: National Interstate Corporation Registration Statement on Form S-1 File Number 333-119270, Amendment No. 5
Dear Mr. Schroeder:
We have reviewed your filing and have the following comments. Where indicated, we think you should revise your document in response to these comments. If you disagree, we will consider your explanation as to why our comment is inapplicable or a revision is unnecessary. Please be as detailed as necessary in your explanation. In some of our comments, we may ask you to provide us with supplemental information so we may better understand your disclosure. After reviewing this information, we may or may not raise additional comments.
Now that we are subject to Securities and Exchange Commission rules and regulations..., page 20
You state that Ernst & Young has characterized your need for improved controls and processes related to financial reporting and need for additional financial reporting resources as a significant deficiency that is not a material weakness. Please describe specifically what conditions and needs caused Ernst & Young to identify the significant deficiency. Also, explain why the significant deficiency did not rise to the level of a material weakness and discuss in greater detail the potential financial impact of the deficiency.
* * * As appropriate, please amend your registration statement in response to these comments. You may wish to provide us with marked copies of the amendment to expedite our review. Please furnish a cover letter with your amendment that keys your responses to our comments and provides any requested supplemental information. Detailed cover letters greatly facilitate our review. Please understand that we may have additional comments after reviewing your amendment and responses to our comments.
You may contact Whitnie Storey at (202) 942-2851 or Jim Atkinson (202) 942-2826 if you have questions regarding comments on the financial statements and related matters. Please contact Michael Reedich at (202) 942-1815 or me at (202) 942-1840 with any other questions.
Sincerely,
Jeffrey Riedler
Assistant Director
Show Raw Text
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Mail Stop 3-09
January 6, 2005
Michael Schroeder
Vice President, Secretary and General Counsel
National Interstate Corporation
3250 Interstate Drive
Richfield, OH 44286-9000
Re: National Interstate Corporation
Registration Statement on Form S-1
File Number 333-119270, Amendment No. 5
Dear Mr. Schroeder:
We have reviewed your filing and have the following
comments.
Where indicated, we think you should revise your document in
response
to these comments. If you disagree, we will consider your
explanation as to why our comment is inapplicable or a revision is
unnecessary. Please be as detailed as necessary in your
explanation.
In some of our comments, we may ask you to provide us with
supplemental information so we may better understand your
disclosure.
After reviewing this information, we may or may not raise
additional
comments.
Now that we are subject to Securities and Exchange Commission
rules
and regulations..., page 20
You state that Ernst & Young has characterized your need for
improved
controls and processes related to financial reporting and need for
additional financial reporting resources as a significant
deficiency
that is not a material weakness. Please describe specifically
what
conditions and needs caused Ernst & Young to identify the
significant
deficiency. Also, explain why the significant deficiency did not
rise to the level of a material weakness and discuss in greater
detail the potential financial impact of the deficiency.
* * *
As appropriate, please amend your registration statement in
response to these comments. You may wish to provide us with
marked
copies of the amendment to expedite our review. Please furnish a
cover letter with your amendment that keys your responses to our
comments and provides any requested supplemental information.
Detailed cover letters greatly facilitate our review. Please
understand that we may have additional comments after reviewing
your
amendment and responses to our comments.
You may contact Whitnie Storey at (202) 942-2851 or Jim
Atkinson (202) 942-2826 if you have questions regarding comments
on
the financial statements and related matters. Please contact
Michael
Reedich at (202) 942-1815 or me at (202) 942-1840 with any other
questions.
Sincerely,
Jeffrey Riedler
Assistant Director
cc: April V. Boise, Esq.
Thompson Hine LLP
127 Public Square, Suite 3900
Cleveland, OH 44114
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