SEC Comment Letter for Republic Companies Group, Inc. (CIK 0001320092) — Jul 11, 2005
Republic Companies Group, Inc. (CIK 0001320092)
Date: July 11, 2005 · CIK: 0001320092 · Accession: 0000000000-05-035115
AI Filing Summary & Sentiment
File numbers found in text: 333-124758
Letter
Via Facsimile and U.S. Mail Mail Stop 6010 July 11, 2005 Parker W. Rush President and Chief Executive Officer Republic Companies Group, Inc. 222 Delaware Avenue, Suite 900 Wilmington, Delaware 19801
Re: Republic Companies Group, Inc. Amendment #1Registration Statement on Form S-1 Filed June 27, 2005 File Number 333-124758
Dear Mr. Rush:
We have reviewed your filing and have the following comment. Please provide us with supplemental information so we may better understand your disclosure. After reviewing this information, we may or may not raise additional comments.
Please understand that the purpose of our review process is to assist you in your compliance with the applicable disclosure requirements and to enhance the overall disclosure in your filing. We look forward to working with you in these respects. We welcome any questions you may have about our comment or on any other aspect of our review. Feel free to call us at the telephone numbers listed at the end of this letter.
FORM S-1
Notes to Consolidated and Combined Financial Statements
Note (2) Organization and Acquisition, Page F-11 1. We have reviewed your response to comment number 48. Please cite the specific accounting literature used by management to justify recording the "discounted present value of the future underwriting profits embedded in the acquired unearned premium reserves, plus the investment earnings associated with the assets supporting the unearned premium reserve and resulting loss reserves" as an asset upon acquisition.
* * *
Please furnish a cover letter with your supplemental information. Detailed cover letters greatly facilitate our review. Please file your cover letter on EDGAR under the form type label CORRESP. Please understand that we may have additional comments after reviewing your response to our comment.
We direct your attention to Rules 460 and 461 regarding requesting acceleration of a registration statement. Please allow adequate time after the filing of any amendment for further review before submitting a request for acceleration. Please provide this request at least two business days in advance of the requested effective date.
You may contact Jason Lawson at (202) 551-3666 or Kevin Woody at (202) 551-3629 if you have questions regarding comments on the financial statements and related matters. Please contact Albert Lee at (202) 551-3654 or me at (202) 551-3715 with any other questions.
Sincerely,
Jeffrey Riedler
Assistant Director
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<DOCUMENT>
<TYPE>LETTER
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<FILENAME>filename1.txt
<TEXT>
Via Facsimile and U.S. Mail
Mail Stop 6010
July 11, 2005
Parker W. Rush
President and Chief Executive Officer
Republic Companies Group, Inc.
222 Delaware Avenue, Suite 900
Wilmington, Delaware 19801
Re: Republic Companies Group, Inc.
Amendment #1Registration Statement on Form S-1
Filed June 27, 2005
File Number 333-124758
Dear Mr. Rush:
We have reviewed your filing and have the following comment.
Please provide us with supplemental information so we may better
understand your disclosure. After reviewing this information, we
may
or may not raise additional comments.
Please understand that the purpose of our review process is
to
assist you in your compliance with the applicable disclosure
requirements and to enhance the overall disclosure in your filing.
We look forward to working with you in these respects. We welcome
any questions you may have about our comment or on any other
aspect
of our review. Feel free to call us at the telephone numbers
listed
at the end of this letter.
FORM S-1
Notes to Consolidated and Combined Financial Statements
Note (2) Organization and Acquisition, Page F-11
1. We have reviewed your response to comment number 48. Please
cite
the specific accounting literature used by management to justify
recording the "discounted present value of the future underwriting
profits embedded in the acquired unearned premium reserves, plus
the
investment earnings associated with the assets supporting the
unearned premium reserve and resulting loss reserves" as an asset
upon acquisition.
* * *
Please furnish a cover letter with your supplemental
information. Detailed cover letters greatly facilitate our
review.
Please file your cover letter on EDGAR under the form type label
CORRESP. Please understand that we may have additional comments
after reviewing your response to our comment.
We direct your attention to Rules 460 and 461 regarding
requesting acceleration of a registration statement. Please allow
adequate time after the filing of any amendment for further review
before submitting a request for acceleration. Please provide this
request at least two business days in advance of the requested
effective date.
You may contact Jason Lawson at (202) 551-3666 or Kevin
Woody
at (202) 551-3629 if you have questions regarding comments on the
financial statements and related matters. Please contact Albert
Lee
at (202) 551-3654 or me at (202) 551-3715 with any other
questions.
Sincerely,
Jeffrey Riedler
Assistant Director
cc: T. Mark Kelly
Vinson & Elkins L.L.P.
First City Tower
1001 Fannin Street, Suite 2300
Houston, Texas 77002
</TEXT>
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