SEC Comment Letter for Presurance Holdings, Inc. (PRHI, PRHIZ) (CIK 0001502292) (PRHI) — May 4, 2018
Presurance Holdings, Inc. (PRHI, PRHIZ) (CIK 0001502292)
Date: May 4, 2018 · CIK: 0001502292 · Accession: 0000000000-18-013925
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 001-37536
Letter
May 4, 2018 Harold Meloche Chief Financial Officer Conifer Holdings, Inc. 550 West Merrill Street, Suite 200 Birmingham, MI 48009 Re:Conifer Holdings, Inc. Form 10-K for the Fiscal Year Ended December 31, 2017 Filed March 15, 2018 File No. 001-37536 Dear Mr. Meloche: We have limited our review of your filing to the financial statements and related disclosures and have the following comment. Please respond to the comment within ten business days by providing the requested information or advise us as soon as possible when you will respond. If you do not believe our comment applies to your facts and circumstances, please tell us why in your response. After reviewing your response to the comment, we may have additional comments. Form 10-K for the Fiscal Year Ended December 31, 2017 Item 15. Exhibits and Financial Statement Schedules, page 53 1.Please amend your filing to provide new certifications filed as Exhibits 31.1 and 31.2 to conform exactly to that provided in Item 601(b)(31) of Regulation S-K as it relates to internal controls over financial reporting (ICFR). In this regard, the introductory sentence in paragraph 4 should refer to ICFR as defined in the Exchange Act and certification 4(b) should discuss your obligations related to ICFR. In closing, we remind you that the company and its management are responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the staff.
FirstName LastNameHarold Meloche Comapany NameConifer Holdings, Inc. June 16, 2017 Page 2 FirstName LastName Harold Meloche Conifer Holdings, Inc. May 4, 2018 Page 2 You may contact Vanessa Robertson at 202-551-3649 or Rolf Sundwall at 202-551-3105 with any questions. Division of Corporation Finance Office of Healthcare & Insurance
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May 4, 2018
Harold Meloche
Chief Financial Officer
Conifer Holdings, Inc.
550 West Merrill Street, Suite 200
Birmingham, MI 48009
Re:Conifer Holdings, Inc.
Form 10-K for the Fiscal Year Ended December 31, 2017
Filed March 15, 2018
File No. 001-37536
Dear Mr. Meloche:
We have limited our review of your filing to the financial statements and related
disclosures and have the following comment.
Please respond to the comment within ten business days by providing the requested
information or advise us as soon as possible when you will respond. If you do not believe our
comment applies to your facts and circumstances, please tell us why in your response.
After reviewing your response to the comment, we may have additional comments.
Form 10-K for the Fiscal Year Ended December 31, 2017
Item 15. Exhibits and Financial Statement Schedules, page 53
1.Please amend your filing to provide new certifications filed as Exhibits 31.1 and 31.2 to
conform exactly to that provided in Item 601(b)(31) of Regulation S-K as it relates to
internal controls over financial reporting (ICFR). In this regard, the introductory sentence
in paragraph 4 should refer to ICFR as defined in the Exchange Act and certification 4(b)
should discuss your obligations related to ICFR.
In closing, we remind you that the company and its management are responsible for the
accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or
absence of action by the staff.
FirstName LastNameHarold Meloche
Comapany NameConifer Holdings, Inc.
June 16, 2017 Page 2
FirstName LastName
Harold Meloche
Conifer Holdings, Inc.
May 4, 2018
Page 2
You may contact Vanessa Robertson at 202-551-3649 or Rolf Sundwall at 202-551-3105
with any questions.
Division of Corporation Finance
Office of Healthcare & Insurance