SEC Comment Letter 0000000000-23-013082 to Conifer Holdings, Inc. (CNFR, CNFRZ) (CIK 0001502292) (PRHI)
Conifer Holdings, Inc. (CNFR, CNFRZ) (CIK 0001502292)
Date: Nov. 30, 2023 · CIK: 0001502292 · Accession: 0000000000-23-013082
AI Filing Summary & Sentiment
File numbers found in text: 001-37536
Letter
United States securities and exchange commission logo November 30, 2023 Harold Meloche Chief Financial Officer Conifer Holdings, Inc. 3001 West Big Beaver Road Suite 200 Troy, MI 48084 Re:Conifer Holdings, Inc. Form 10-K For Fiscal Year Ended December 31, 2022 Filed March 27, 2023 File No. 001-37536 Dear Harold Meloche: We have limited our review of your filing to the financial statements and related disclosures and have the following comment. Please respond to this letter 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 a comment applies to your facts and circumstances, please tell us why in your response. After reviewing your response to this letter, we may have additional comments. Form 10-K filed March 27,2023 Non-GAAP Financial Measures, page 44 1.In the reconciliations of your non-GAAP financial measures, we note that you present adjustments "net of tax." Please revise your disclosures and reconciliations, in future filings, to present income taxes as a separate adjustment and to provide a clear explanation of how the tax impacts are calculated. Refer to Question 102.11 of the Non-GAAP Financial Measures Compliance & Disclosure Interpretations.
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. Please contact Lory Empie at 202-551-3714 or Robert Klein at 202-551-3847 with any questions.
FirstName LastNameHarold Meloche Comapany NameConifer Holdings, Inc. November 30, 2023 Page 2 FirstName LastName Harold Meloche Conifer Holdings, Inc. November 30, 2023 Page 2 Sincerely, Division of Corporation Finance Office of Finance
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United States securities and exchange commission logo
November 30, 2023
Harold Meloche
Chief Financial Officer
Conifer Holdings, Inc.
3001 West Big Beaver Road
Suite 200
Troy, MI 48084
Re:Conifer Holdings, Inc.
Form 10-K For Fiscal Year Ended December 31, 2022
Filed March 27, 2023
File No. 001-37536
Dear Harold Meloche:
We have limited our review of your filing to the financial statements and related
disclosures and have the following comment.
Please respond to this letter 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 a
comment applies to your facts and circumstances, please tell us why in your response.
After reviewing your response to this letter, we may have additional comments.
Form 10-K filed March 27,2023
Non-GAAP Financial Measures, page 44
1.In the reconciliations of your non-GAAP financial measures, we note that you present
adjustments "net of tax." Please revise your disclosures and reconciliations, in future
filings, to present income taxes as a separate adjustment and to provide a clear explanation
of how the tax impacts are calculated. Refer to Question 102.11 of the Non-GAAP
Financial Measures Compliance & Disclosure Interpretations.
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.
Please contact Lory Empie at 202-551-3714 or Robert Klein at 202-551-3847 with any
questions.
FirstName LastNameHarold Meloche
Comapany NameConifer Holdings, Inc.
November 30, 2023 Page 2
FirstName LastName
Harold Meloche
Conifer Holdings, Inc.
November 30, 2023
Page 2
Sincerely,
Division of Corporation Finance
Office of Finance