Correspondence 0000950170-24-003643 from Conifer Holdings, Inc. (CNFR, CNFRZ) (CIK 0001502292) (PRHI)
Conifer Holdings, Inc. (CNFR, CNFRZ) (CIK 0001502292)
Date: Jan. 10, 2024 · CIK: 0001502292 · Accession: 0000950170-24-003643
AI Filing Summary & Sentiment
File numbers found in text: 001-37536
Referenced dates: November 30, 2023
Letter
Division of Corporation Finance Office of Healthcare & Insurance Attention: Lorie Empie Conifer Holdings, Inc. Form 10-K for Fiscal Year Ended December 31, 2022 Filed March 27, 2023 File No. 001-37536
Dear Ms. Empie and Mr. Klein:
I submit this letter on behalf of Conifer Holdings, Inc. (the “Company”) in response to the comment letter of the Staff of the Securities and Exchange Commission dated November 30, 2023 (the “Comment Letter”) relating to the Company’s Annual Report on Form 10-K for the year ended December 31, 2022 (the “2022 Form 10-K”).
For your convenience, we have included the text of the applicable comment in the Comment Letter in bold immediately before our response.
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.
The Company advises the Staff that when disclosing income taxes the Company will disclose income taxes as a separate adjustment and provide a clear explanation of how the tax impacts are calculated.
We hope that the foregoing has been responsive to the Staff’s comment. Please direct any questions regarding this letter to Donald J. Kunz at (313) 465-7454 or via e-mail at dkunz@honigman.com if you have any comments or questions about this letter.
Very truly yours,
/s/ Richard Fiato
Show Raw Text
CORRESP
1
filename1.htm
CORRESP
January 10, 2024
U.S. Securities and Exchange Commission
Division of Corporation Finance
Office of Healthcare & Insurance
100 F. Street, N.E.
Washington, D.C. 20549
Attention: Lorie Empie
Robert Klein
Re:
Conifer Holdings, Inc.
Form 10-K for Fiscal Year Ended December 31, 2022
Filed March 27, 2023
File No. 001-37536
Dear Ms. Empie and Mr. Klein:
I submit this letter on behalf of Conifer Holdings, Inc. (the “Company”) in response to the comment letter of the Staff of the Securities and Exchange Commission dated November 30, 2023 (the “Comment Letter”) relating to the Company’s Annual Report on Form 10-K for the year ended December 31, 2022 (the “2022 Form 10-K”).
For your convenience, we have included the text of the applicable comment in the Comment Letter in bold immediately before our response.
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.
The Company advises the Staff that when disclosing income taxes the Company will disclose income taxes as a separate adjustment and provide a clear explanation of how the tax impacts are calculated.
We hope that the foregoing has been responsive to the Staff’s comment. Please direct any questions regarding this letter to Donald J. Kunz at (313) 465-7454 or via e-mail at dkunz@honigman.com if you have any comments or questions about this letter.
Very truly yours,
/s/ Richard Fiato
Richard Fiato
Corporate Counsel
Conifer Holdings, Inc.
cc: Donald J. Kunz
(Honigman LLP)