SEC Company Response from Global Indemnity Group, LLC (GBLI) (CIK 0001494904) (GBLI) — Oct 9, 2012
Global Indemnity Group, LLC (GBLI) (CIK 0001494904)
Date: Oct. 9, 2012 · CIK: 0001494904 · Accession: 0001193125-12-418061
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 001-34809
Referenced dates: September 26, 2012
Letter
VIA EDGAR Division of Corporation Finance United States Securities and Exchange Commission RE: Global Indemnity plc Form 10-K for the Fiscal Year Ended December 31, 2011 Filed March 14, 2012 File No. 001-34809
Dear Mr. Riedler:
On behalf of Global Indemnity plc (the “Company”), I am providing the following response to the additional comment made in the Staff’s letter dated September 26, 2012 regarding the Company’s Annual Report on Form 10-K for the fiscal year ended December 31, 2011, filed on March 14, 2012. To assist in your review, the text of the comment is repeated below with the Company’s response immediately following.
General
1. We note your response to our prior Comment 1 regarding disclosure of quantitative information by product line or groups of similar products. In your Business section, you mention property, casualty, professional lines and general liability and in your MD&A section you also mention automobile liability, workers’ compensation and umbrella product lines. As we previously noted, the transcript of your earnings call for the fiscal year ended December 31, 2011 indicates substantial interest in how the various product lines you offer affected your overall financial results for fiscal 2011. While it may not be feasible to disclose profitability by product line or groups of similar products, as you have indicated that operating profitability is distinctly measured at the segment level, please consider reporting revenue-related information by product line or groups of similar products. In this regard, please tell us what further information you may be able to include in future filings to present investors with a clearer picture of the revenue-generating performance of your various product lines and provide us with proposed disclosure for future filings.
In response to the Staff’s Comment, the Company, prospectively, will include revenue-related information by product line or groups of similar products in tabular format within the MD&A section under the “Premiums” discussion for each segment and period. The following table disclosing gross written, net written and net earned premiums by product line for each segment will be presented. If there are any significant fluctuations for these product lines, the reasons will be noted in paragraphs following the table.
(Dollars in thousands)
Quarter Ended September 30, 2012
Quarter Ended September 30, 2011
Gross Written
Net Written
Net Earned
Gross Written
Net Written
Net Earned
Product Line or Group 1
$ xxx
$ xxx
$ xxx
$ xxx
$ xxx
$ xxx
Product Line or Group 2
Xxx
Xxx
Xxx
Xxx
Xxx
Xxx
Product Line or Group 3
Xxx
Xxx
Xxx
Xxx
Xxx
Xxx
Total
$ xxx
$ xxx
$ xxx
$ xxx
$ xxx
$ xxx
The Company believes that this tabular presentation of revenue-related information by product line will assist investors in understanding the relationship between the Company’s various product lines and the overall financial results of the Company for a given period.
The Company is aware of its obligations under the Securities Exchange Act of 1934, as amended.
The Company, as you requested, further acknowledges that:
•
it is responsible for the adequacy and accuracy of the disclosure in the filings;
•
staff comments or changes to disclosure in response to staff comments do not foreclose the Commission from taking any action with respect to the filings; and
•
the Company may not assert staff comments as a defense in any proceedings initiated by the Commission or any person under the federal securities laws of the United States.
Please do not hesitate to call the undersigned at (610) 664-1500 with any questions or further comments you may have regarding this filing or if you wish to discuss the above response.
Very truly yours,
/s/ Cynthia Y. Valko
Show Raw Text
CORRESP 1 filename1.htm Correspondence October 9, 2012 VIA EDGAR Mr. Jeffrey P. Riedler Assistant Director Division of Corporation Finance United States Securities and Exchange Commission 100 F Street, N.E. Washington, D.C. 20549 RE: Global Indemnity plc Form 10-K for the Fiscal Year Ended December 31, 2011 Filed March 14, 2012 File No. 001-34809 Dear Mr. Riedler: On behalf of Global Indemnity plc (the “Company”), I am providing the following response to the additional comment made in the Staff’s letter dated September 26, 2012 regarding the Company’s Annual Report on Form 10-K for the fiscal year ended December 31, 2011, filed on March 14, 2012. To assist in your review, the text of the comment is repeated below with the Company’s response immediately following. General 1. We note your response to our prior Comment 1 regarding disclosure of quantitative information by product line or groups of similar products. In your Business section, you mention property, casualty, professional lines and general liability and in your MD&A section you also mention automobile liability, workers’ compensation and umbrella product lines. As we previously noted, the transcript of your earnings call for the fiscal year ended December 31, 2011 indicates substantial interest in how the various product lines you offer affected your overall financial results for fiscal 2011. While it may not be feasible to disclose profitability by product line or groups of similar products, as you have indicated that operating profitability is distinctly measured at the segment level, please consider reporting revenue-related information by product line or groups of similar products. In this regard, please tell us what further information you may be able to include in future filings to present investors with a clearer picture of the revenue-generating performance of your various product lines and provide us with proposed disclosure for future filings. In response to the Staff’s Comment, the Company, prospectively, will include revenue-related information by product line or groups of similar products in tabular format within the MD&A section under the “Premiums” discussion for each segment and period. The following table disclosing gross written, net written and net earned premiums by product line for each segment will be presented. If there are any significant fluctuations for these product lines, the reasons will be noted in paragraphs following the table. (Dollars in thousands) Quarter Ended September 30, 2012 Quarter Ended September 30, 2011 Gross Written Net Written Net Earned Gross Written Net Written Net Earned Product Line or Group 1 $ xxx $ xxx $ xxx $ xxx $ xxx $ xxx Product Line or Group 2 Xxx Xxx Xxx Xxx Xxx Xxx Product Line or Group 3 Xxx Xxx Xxx Xxx Xxx Xxx Total $ xxx $ xxx $ xxx $ xxx $ xxx $ xxx The Company believes that this tabular presentation of revenue-related information by product line will assist investors in understanding the relationship between the Company’s various product lines and the overall financial results of the Company for a given period. The Company is aware of its obligations under the Securities Exchange Act of 1934, as amended. The Company, as you requested, further acknowledges that: • it is responsible for the adequacy and accuracy of the disclosure in the filings; • staff comments or changes to disclosure in response to staff comments do not foreclose the Commission from taking any action with respect to the filings; and • the Company may not assert staff comments as a defense in any proceedings initiated by the Commission or any person under the federal securities laws of the United States. Please do not hesitate to call the undersigned at (610) 664-1500 with any questions or further comments you may have regarding this filing or if you wish to discuss the above response. Very truly yours, /s/ Cynthia Y. Valko Cynthia Y. Valko cc: Nandini Acharaya, Attorney Advisor Thomas M. McGeehan, Global Indemnity plc Linda C. Hohn, Global Indemnity plc