SEC Comment Letter for Global Indemnity Group, LLC (GBLI) (CIK 0001494904) (GBLI) — Aug 9, 2018
Global Indemnity Group, LLC (GBLI) (CIK 0001494904)
Date: Aug. 9, 2018 · CIK: 0001494904 · Accession: 0000000000-18-024642
AI Filing Summary & Sentiment
File numbers found in text: 333-225758
Letter
August 8, 2018 Cynthia Y. Valko Chief Executive Officer Global Indemnity Limited 27 Hospital Road George Town, Grand Cayman KY1-9008 Cayman Islands Re:Global Indemnity Limited Amendment No. 1 to Registration Statement on Form S-3 Filed August 1, 2018 File No. 333-225758 Dear Ms. Valko: We have reviewed your amended registration statement and have the following comments. In some of our comments, we may ask you to provide us with information so we may better understand your disclosure. Please respond to this letter by amending your registration statement and providing the requested information. If you do not believe our comments apply 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 these comments, we may have additional comments. Amendment No. 1 to Form S-3 filed August 1, 2018 Description of the Debt Securities, page 16 1.We note your disclosure on pages 16 and 27 that the debt securities that may be issued by the Company and GIGI, as co-obligors, may be convertible. Please explain how this meets the requirement in Instruction I.C.4 of Form S-3 that the securities being registered are non-convertible securities.
FirstName LastNameCynthia Y. Valko Comapany NameGlobal Indemnity Limited August 8, 2018 Page 2 FirstName LastName Cynthia Y. Valko Global Indemnity Limited August 8, 2018 Page 2 Please contact Ada D. Sarmento at 202-551-3798 or Erin Jaskot at 202-551-3442 with any questions. Sincerely, Division of Corporation Finance Office of Healthcare & Insurance cc: Megan J. Baier, Esq.
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August 8, 2018
Cynthia Y. Valko
Chief Executive Officer
Global Indemnity Limited
27 Hospital Road
George Town, Grand Cayman
KY1-9008
Cayman Islands
Re:Global Indemnity Limited
Amendment No. 1 to Registration Statement on Form S-3
Filed August 1, 2018
File No. 333-225758
Dear Ms. Valko:
We have reviewed your amended registration statement and have the following
comments. In some of our comments, we may ask you to provide us with information so we
may better understand your disclosure.
Please respond to this letter by amending your registration statement and providing the
requested information. If you do not believe our comments apply 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 these comments, we may have additional comments.
Amendment No. 1 to Form S-3 filed August 1, 2018
Description of the Debt Securities, page 16
1.We note your disclosure on pages 16 and 27 that the debt securities that may be issued by
the Company and GIGI, as co-obligors, may be convertible. Please explain how this
meets the requirement in Instruction I.C.4 of Form S-3 that the securities being registered
are non-convertible securities.
FirstName LastNameCynthia Y. Valko
Comapany NameGlobal Indemnity Limited
August 8, 2018 Page 2
FirstName LastName
Cynthia Y. Valko
Global Indemnity Limited
August 8, 2018
Page 2
Please contact Ada D. Sarmento at 202-551-3798 or Erin Jaskot at 202-551-3442 with
any questions.
Sincerely,
Division of Corporation Finance
Office of Healthcare & Insurance
cc: Megan J. Baier, Esq.