SEC Company Response from Heritage Insurance Holdings, Inc. (HRTG) (CIK 0001598665) (HRTG) — Jan 8, 2020
Heritage Insurance Holdings, Inc. (HRTG) (CIK 0001598665)
Date: Jan. 8, 2020 · CIK: 0001598665 · Accession: 0001193125-20-003686
AI Filing Summary & Sentiment
File numbers found in text: 001-36462
Referenced dates: December 11, 2019
Letter
Division of Corporation Finance Office of Finance United States Securities and Exchange Commission Re: Heritage Insurance Holdings, Inc. Form 10-K for the Fiscal Year Ended December 31, 2018 Filed March 12, 2019 File No. 001-36462
Dear Ms. Baines and Mr. Brunhofer,
Heritage Insurance Holdings, Inc. (the “Company” or “we”) has reviewed the comments in the Staff’s letter, dated December 11, 2019, regarding the Company’s Form 10-K for the fiscal year ended December 31, 2018 (the “2018 Form 10-K”). Set forth below are the responses of the Company. For convenience of reference, the text of the comments in the Staff’s letter has been reproduced in italics below.
Form 10-K for the Fiscal Year Ended December 31, 2018
Management’s Discussion and Analysis of Financial Condition and Results of Operations
Critical Accounting Policies and Estimates
Reserves for Unpaid Losses and Loss Adjustment Expenses, Page 52
1. We acknowledge your response to prior comment 1 and your efforts to streamline your unpaid losses and loss adjustment expenses disclosures in Management’s Discussion and Analysis in light of the guidance in Section V of Release No. 33-8350 that states such disclosures should supplement, and not duplicate, the description of accounting policies already disclosed in the financial statements. While we note the disclosures referenced in your response, none of these disclosures provide the quantitative forward-looking sensitivity analysis called for in the referenced guidance for critical accounting estimates. We also note that the provision of the actuarial range associated with the most recent loss reserve estimate is but one way to provide the quantitative analysis of reasonably likely changes in the key underlying reserving assumptions. Please represent to us that in future filings on Form 10-K you will either reinstate your actuarial loss range disclosure or that you will provide some other quantitative sensitivity analysis of the impact on reported results, financial position and liquidity of reasonably likely changes in the key assumptions underlying your most recent estimate of reserves for unpaid losses and loss adjustment expenses.
Response: In response to the Staff’s comment, the Company will, in future Annual Reports on Form 10-K, beginning with its Annual Report on Form 10-K for the fiscal year ended December 31, 2019, either reinstate its actuarial loss range disclosure or include some other quantitative sensitivity analysis of the impact on reported results, financial position and liquidity of reasonably likely changes in the key assumptions underlying the Company’s most recent estimate of reserves for unpaid losses and loss adjustment expenses.
If you have any questions regarding any of the responses in this letter, please call the undersigned at 727-362-7211.
Respectfully submitted,
/s/ Kirk Lusk
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CORRESP 1 filename1.htm CORRESP Heritage Insurance Holdings, Inc. 2600 McCormick Dr., Suite 300 Clearwater, FL 33759 Telephone: 727-362-7211 www.heritagepci.com January 8, 2020 Ms. Bonnie Baines Mr. Mark Brunhofer Division of Corporation Finance Office of Finance United States Securities and Exchange Commission Washington, D.C. 20549 Re: Heritage Insurance Holdings, Inc. Form 10-K for the Fiscal Year Ended December 31, 2018 Filed March 12, 2019 File No. 001-36462 Dear Ms. Baines and Mr. Brunhofer, Heritage Insurance Holdings, Inc. (the “Company” or “we”) has reviewed the comments in the Staff’s letter, dated December 11, 2019, regarding the Company’s Form 10-K for the fiscal year ended December 31, 2018 (the “2018 Form 10-K”). Set forth below are the responses of the Company. For convenience of reference, the text of the comments in the Staff’s letter has been reproduced in italics below. Form 10-K for the Fiscal Year Ended December 31, 2018 Management’s Discussion and Analysis of Financial Condition and Results of Operations Critical Accounting Policies and Estimates Reserves for Unpaid Losses and Loss Adjustment Expenses, Page 52 1. We acknowledge your response to prior comment 1 and your efforts to streamline your unpaid losses and loss adjustment expenses disclosures in Management’s Discussion and Analysis in light of the guidance in Section V of Release No. 33-8350 that states such disclosures should supplement, and not duplicate, the description of accounting policies already disclosed in the financial statements. While we note the disclosures referenced in your response, none of these disclosures provide the quantitative forward-looking sensitivity analysis called for in the referenced guidance for critical accounting estimates. We also note that the provision of the actuarial range associated with the most recent loss reserve estimate is but one way to provide the quantitative analysis of reasonably likely changes in the key underlying reserving assumptions. Please represent to us that in future filings on Form 10-K you will either reinstate your actuarial loss range disclosure or that you will provide some other quantitative sensitivity analysis of the impact on reported results, financial position and liquidity of reasonably likely changes in the key assumptions underlying your most recent estimate of reserves for unpaid losses and loss adjustment expenses. Response: In response to the Staff’s comment, the Company will, in future Annual Reports on Form 10-K, beginning with its Annual Report on Form 10-K for the fiscal year ended December 31, 2019, either reinstate its actuarial loss range disclosure or include some other quantitative sensitivity analysis of the impact on reported results, financial position and liquidity of reasonably likely changes in the key assumptions underlying the Company’s most recent estimate of reserves for unpaid losses and loss adjustment expenses. If you have any questions regarding any of the responses in this letter, please call the undersigned at 727-362-7211. Respectfully submitted, /s/ Kirk Lusk Kirk Lusk Chief Financial Officer Cc: Flora R. Perez, Esquire (Greenberg Traurig, P.A.)