SEC Comment Letter 0000000000-23-006458 to RYAN SPECIALTY HOLDINGS, INC. (RYAN) (CIK 0001849253) (RYAN)
RYAN SPECIALTY HOLDINGS, INC. (RYAN) (CIK 0001849253)
Date: June 15, 2023 · CIK: 0001849253 · Accession: 0000000000-23-006458
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File numbers found in text: 001-40645
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United States securities and exchange commission logo
June 15, 2023
Jeremiah R. Bickham
Executive Vice President and Chief Financial Officer
Ryan Specialty Holdings, Inc.
Two Prudential Plaza
180 N. Stetson Avenue
Suite 4600
Chicago, IL 60601
Re:Ryan Specialty Holdings, Inc.
Form 10-K for the Fiscal Year Ended December 31, 2022
Filed March 1, 2023
Form 10-Q for the Quarterly Period Ended March 31, 2023
Filed May 5, 2023
File No. 001-40645
Dear Jeremiah R. Bickham:
We have limited our review of your filings to the financial statements and related
disclosures and have the following comments. In some of our comments, we may ask you to
provide us with information so we may better understand your disclosure.
Please respond to these comments 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
comments apply to your facts and circumstances, please tell us why in your response.
After reviewing your response to these comments, we may have additional comments.
Form 10-K for the Year Ended December 31, 2022
Item 7. Management Discussion and Analysis of Financial Condition and Results of Operations
Critical Accounting Policies and Estimates, page 78
1.In future filings, please revise your Critical Accounting Policies and Estimates section to
include quantitative information necessary to understand the estimation uncertainty and
the impact the critical accounting estimate has had or is reasonably likely to have on
financial condition or results of operations. Refer to Item 303(b)(3) of Regulation S-K.
Form 10-Q for the Quarterly Period Ended March 31, 2023
FirstName LastNameJeremiah R. Bickham
Comapany NameRyan Specialty Holdings, Inc.
June 15, 2023 Page 2
FirstName LastName
Jeremiah R. Bickham
Ryan Specialty Holdings, Inc.
June 15, 2023
Page 2
Item 2. Management's Discussion and Analysis of Financial Condition and Results of Operations
Revenue, page 27
2.In future filings, please expand your revenue discussion to provide additional details
around trends impacting your results of operations and to quantify the extent to which
changes are attributable to changes in price, volume, specific product, industry class, or
other market factors. For example, we note that your current disclosures identify various
line item drivers, such as organic growth within Specialties, new business, acquisitions,
new products, and inflow of risks from the Admitted market into the E&S market, but do
not provide quantification, context, and clarity into the amounts and product areas (e.g.,
property, casualty, personal lines, etc.) related to these drivers. Refer to Item
303(b)(2)(iii) of Regulation S-K.
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.
You may contact Sarmad Makhdoom at 202-551-5776 or Cara Lubit at 202-551-5909
with any questions.
Sincerely,
Division of Corporation Finance
Office of Finance