SEC Comment Letter for Global Indemnity Group, LLC (GBLI) (CIK 0001494904) (GBLI) — Jul 13, 2015
Global Indemnity Group, LLC (GBLI) (CIK 0001494904)
Date: July 13, 2015 · CIK: 0001494904 · Accession: 0000000000-15-036375
AI Filing Summary & Sentiment
File numbers found in text: 333-205451
Letter
July 13, 2015 Via E -mail Thomas M. McGeehan Chief Financial Officer c/o Global Indemnity Group, Inc. Three Bala Plaza East, Suite 300 Bala Cynwyd, P ennsylvania 19004
Re: Global Indemnity plc Registration Statement on Form S-3 Filed July 2 , 2015 File No. 333-205451
Dear Mr. McGeehan :
This is to advise you that we have not reviewed and will not review your registration statement .
We urge all persons who are responsible for the accuracy and adequacy of the disclosure in the filing to be certain that the filing includes the information the Securities Act of 193 3 and all applicable Securities Act rules require. Since the company and its management are in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy and adequacy of the disclosures they have made.
In the event you request acceleration of t he effective date of the pending regist ration statement please provide a written statement from the company acknowledging that:
should the Commission or the staff, acting pursuant to delegated authority, declare the filing effective, it does not foreclose the Commission from taking any action with respect to the filing;
the action of the Commission or the staff, acting pursuant to delegated authority, in declaring the filing effective, does not relieve the company from its full responsibility for the ade quacy and accuracy of the disclosure in the filing; and
the company may not assert staff comments and the declaration of effectiveness as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the Unite d States.
Please refer to Rules 460 and 461 regarding requests for acceleration . We will consider a written request for acceleration of the effective date of the registration statement as confirmation of the fact that those requesting acceleration are aw are of their respective responsibilities under
Thomas M. McGeehan Global Indemnity Group, Inc. July 1 3, 2015 Page 2
the Securities Act of 1933 and the Securities Exchange Act of 1934 as they relate to the proposed public offering of the registered securities .
You may contact Tara Keating Brooks at (202) 551 -8336 or me at (202) 551 -3715 with any questions.
Sincerely,
/s/ Jeffrey P. Riedler
Show Raw Text
July 13, 2015 Via E -mail Thomas M. McGeehan Chief Financial Officer c/o Global Indemnity Group, Inc. Three Bala Plaza East, Suite 300 Bala Cynwyd, P ennsylvania 19004 Re: Global Indemnity plc Registration Statement on Form S-3 Filed July 2 , 2015 File No. 333-205451 Dear Mr. McGeehan : This is to advise you that we have not reviewed and will not review your registration statement . We urge all persons who are responsible for the accuracy and adequacy of the disclosure in the filing to be certain that the filing includes the information the Securities Act of 193 3 and all applicable Securities Act rules require. Since the company and its management are in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy and adequacy of the disclosures they have made. In the event you request acceleration of t he effective date of the pending regist ration statement please provide a written statement from the company acknowledging that: should the Commission or the staff, acting pursuant to delegated authority, declare the filing effective, it does not foreclose the Commission from taking any action with respect to the filing; the action of the Commission or the staff, acting pursuant to delegated authority, in declaring the filing effective, does not relieve the company from its full responsibility for the ade quacy and accuracy of the disclosure in the filing; and the company may not assert staff comments and the declaration of effectiveness as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the Unite d States. Please refer to Rules 460 and 461 regarding requests for acceleration . We will consider a written request for acceleration of the effective date of the registration statement as confirmation of the fact that those requesting acceleration are aw are of their respective responsibilities under Thomas M. McGeehan Global Indemnity Group, Inc. July 1 3, 2015 Page 2 the Securities Act of 1933 and the Securities Exchange Act of 1934 as they relate to the proposed public offering of the registered securities . You may contact Tara Keating Brooks at (202) 551 -8336 or me at (202) 551 -3715 with any questions. Sincerely, /s/ Jeffrey P. Riedler Jeffrey P. Riedler Assistant Director cc: Via E -mail Jonathan Ko Skadden, Arps, Slate, Meagher & Flom LLP