SecProbe.io

August 22, 2024
Bruce Lucas
Chief Executive Officer
Slide Insurance Holdings, Inc.
4221 W. Boy Scout Blvd.
Tampa, FL 33607
Re:Slide Insurance Holdings, Inc.
Draft Registration Statement on Form S-1
Submitted August 5, 2024
CIK No. 0001886428
Dear Bruce Lucas:
            We have reviewed your amended draft registration statement and have the following
comments.
            Please respond to this letter by providing the requested information and either submitting
an amended draft registration statement or publicly filing your registration statement on EDGAR.
If you do not believe a comment applies to your facts and circumstances or do not believe an
amendment is appropriate, please tell us why in your response.
            After reviewing the information you provide in response to this letter and your amended
draft registration statement or filed registration statement, we may have additional
comments. Unless we note otherwise, any references to prior comments are to comments in our
July 16, 2024 letter.
Draft Registration Statement on Form S-1
Prospectus Summary, page 1
1.We note your response to prior comment 3 and revised disclosure following the statement
that you believe you have a significant technological advantage. It is unclear if you
believe other companies' technologies do not allow them to estimate future costs and
compare back to base rates to "better understand profitability in real time on an individual
risk basis and to assess large and/or bulk transactions." It is also unclear if you believe
other companies' technologies do not permit them to only select policies that they "believe
to be profitable" based on metrics such as "future reinsurance and AOP costs." Please
provide a basis for the statement that you have "a significant technological advantage."

August 22, 2024
Page 2
Our Organizational Structure, page 9
2.We note your response to prior comments 6, 9 and 11. We also note from your
disclosure concerning Slide Specialty Insurance Inc . that you do not believe you will
receive regulatory approval to be licensed in the State of South Carolina prior to the
effectiveness of the registration statement. However, your organization chart, reflecting
your structure immediately following the IPO, includes Slide Specialty Insurance.
Additionally, it appears from the revised definitional disclosure on page 15 that Slide
Specialty is no longer part of a "Carrier"; however, you continue to state in the last
paragraph on page 21 and imply elsewhere that your "Carrier is legally permitted to write
insurance" in South Carolina. Please revise to clarify the regulatory nature of insurance
underwriting prior to regulatory approval. Please also clarify, if necessary, the extent to
which "admitted" carrier status plays a part in the transition to underwriting insurance
prior to regulatory approval.
Risk Factors, page 15
3.We note your response to comment 5. Please revise to include a new risk factor or expand
the third risk factor on page 31 to further clarify the risks associated with being
concentrated in two "coastal specialty zone" states. We note the statement in
your response to comment 5 that other insurers choose to minimize exposure to the unique
risks and environmental challenges of those areas. We also note that the first full risk
factor on page 50 mentions hurricanes and other east coast-related risks but appears
generally applicable to homeowner insurance businesses and a wide range of risks from,
for example, tsunamis, earthquakes, terrorism or war. Your revised risk factor should
address the specific risks, if material, in South Carolina and Florida of regulatory and
legislative bodies "restrict[ing] certain policy non-renewals or cancellations and
require[ing] advance notice of certain policy non-renewals ... or limit[ing] or
delay[ing] rate changes for a specified period during or after a catastrophe event," as
referenced on page 104.
Management's Discussion and Analysis of Financial Condition and Results of Operations, page
72
4.We note your response to prior comment 19 and reissue. Please revise your Management's
Discussion and Analysis of Financial Condition and Results of Operations to discuss your
financial condition. Specifically, please discuss and analyze material line items, and
material changes period-over-period in those line items, on your consolidated balance
sheets, as well as the underlying reasons for those material changes in quantitative and
qualitative terms. Please refer to Item 303 of Regulation S-K.
Expenses, page 81
5.We note your response to prior comment 22 and reissue. For instance we note General
and administrative expenses increased year-over-year from $39 million in 2022 to $88
million in 2023 (a 125% increase). Please revise to quantify the primary amounts driving
the period over period changes within the General and administrative expenses line
item. Refer to Item 303 of Regulation S-K.

August 22, 2024
Page 3
Business
Underwriting, page 94
6.We note your disclosure on page 94 that each member of your Underwriting Advisory
Counsel has employment agreements. To the extent you have compensation or other
agreements with directors or officers on the underwriting team, please confirm you have
filed such agreements under Item 601(b)(10) of Regulation S-K.
Government Regulation, page 102
7.We note your response to prior comment 29 and revised disclosure on page 104 with
additional discussion of regulation in Florida. Please revise your Government Regulation
disclosure beginning on page 102, or where appropriate, to further describe the economic
and regulatory environment as they relate to South Carolina.
Notes to Consolidated Financial Statements
1. Nature of Business and Significant Accounting Policies, page F-9
8.We note your response to prior comment 33. We also note your revised disclosure on
page 80 which clarifies that policies from Citizens were assumed, whereas policies from
St. Johns Insurance Company and UPC were acquired. Please also revise your disclosure
to summarize your initial recognition and measurement of acquired policies. Please tell us
the authoritative guidance upon which you relied.
            Please contact Katharine Garrett at 202-551-2332 or Lory Empie at 202-551-3714 if you
have questions regarding comments on the financial statements and related matters. Please
contact Aisha Adegbuyi at 202-551-8754 or James Lopez at 202-551-3536 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Finance
cc:Richard D. Truesdell, Jr., Esq.