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SEC Comment Letter 0000000000-25-003098 to Slide Insurance Holdings, Inc. (SLDE)

Slide Insurance Holdings, Inc.
Date: March 21, 2025 · CIK: 0001886428 · Accession: 0000000000-25-003098

AI Filing Summary & Sentiment

Sentiment
Urgency
Document Type
Confidence
SEC Posture
Company Posture

Summary

Reasoning

Date
March 21, 2025
Author
Division of
Form
UPLOAD
Company
Slide Insurance Holdings, Inc.

Letter

Re: Slide Insurance Holdings, Inc. Amendment No. 4 to Draft Registration Statement on Form S-1 Submitted March 10, 2025 CIK No. 0001886428 Dear Bruce Lucas:

March 21, 2025

Bruce Lucas Chief Executive Officer Slide Insurance Holdings, Inc. 4221 W. Boy Scout Blvd. Tampa, FL 33607

We have reviewed your amended registration statement and have the following comments.

Please respond to this letter by amending your registration statement and providing the requested information. 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 any amendment to your registration statement and the information you provide in response to this letter, we may have additional comments. Unless we note otherwise, any references to prior comments are to comments in our February 21, 2025 letter.

Amendment No. 4 to Draft Registration Statement on Form S-1 Management's Discussion and Analysis of Financial Condition and Results of Operations Revenue, page 78

1. We note your disclosure on page 78 that states The increase in net premiums written was primarily a result of new policies written resulting from acquired renewal rights of Florida homeowners policies with effective dates of February 2024 and later . Please tell us and revise your filing to more clearly explain why new Farmers policies were only written for homeowners policies with effective dates of February 2024 and later to provide more clarity around the significance of this date. 2. We note your response to prior comment 4. We are continuing to evaluate this item and may have further comment. March 21, 2025 Page 2

Report of Independent Registered Public Accounting Firm, page F-2

3. Based on Amendment No. 3 to your Draft Registration Statement on Form S-1 submitted January 22, 2025, we note your auditor, FORVIS, LLP, audited your financial statements as of and for the year ended December 31, 2023. Given that your consolidated financial statements are now presented as of and for the years ended December 31, 2024 and December 31, 2023, please revise your filing to include an updated audit opinion that covers the two years ended December 31, 2024. Refer to Item 2-02(a)(4) of Regulation S-X for guidance. Consolidated Statements of Changes in Shareholders' Equity, page F-6

4. We note your presentation of an Other financing activities line item. Please tell us, and revise your filing to describe, if material, what this amount represents and discuss the related accounting treatment. Consolidated Statements of Cash Flows, page F-7

5. We note your presentation of $5.6 million in Other financing activities as a component of cash flows from investing activities, as well as your presentation of $5.6 million in Other financing costs as a component of cash flows from financing activities. Please explain if and how these amounts are related. Also tell us how you determined that these items were investing and financing activities, respectively, or revise your filing as necessary. General

6. We note the statement on page 5 that, as of December 31, 2024, Citizens Insurance had 936,182 policies, which appears to be a significant decline from a year prior and the previously-disclosed 1.5 million policies. You continue to state you believe Citizens will provide "continuous growth opportunities for years to come." However, we also note the statement on page 16 that "[o]pportunities to acquire large numbers of policies from Citizens meeting our strict underwriting criteria have diminished in recent months." To the extent this is a material trend or uncertainty, please revise MD&A as appropriate. Additionally, please revise where appropriate to further clarify the process and trends related to "Citizens takeouts." Please contact Shannon Davis at 202-551-6687 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.

Show Raw Text
<DOCUMENT>
<TYPE>TEXT-EXTRACT
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<TEXT>
 March 21, 2025

Bruce Lucas
Chief Executive Officer
Slide Insurance Holdings, Inc.
4221 W. Boy Scout Blvd.
Tampa, FL 33607

 Re: Slide Insurance Holdings, Inc.
 Amendment No. 4 to Draft Registration Statement on Form S-1
 Submitted March 10, 2025
 CIK No. 0001886428
Dear Bruce Lucas:

 We have reviewed your amended registration statement and have the
following
comments.

 Please respond to this letter by amending your registration statement
and providing
the requested information. 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 any amendment to your registration statement and the
information
you provide in response to this letter, we may have additional comments. Unless
we note
otherwise, any references to prior comments are to comments in our February 21,
2025 letter.

Amendment No. 4 to Draft Registration Statement on Form S-1
Management's Discussion and Analysis of Financial Condition and Results of
Operations
Revenue, page 78

1. We note your disclosure on page 78 that states The increase in net
premiums written
 was primarily a result of new policies written resulting from acquired
renewal rights
 of Florida homeowners policies with effective dates of February 2024
and later .
 Please tell us and revise your filing to more clearly explain why new
Farmers policies
 were only written for homeowners policies with effective dates of
February 2024 and
 later to provide more clarity around the significance of this date.
2. We note your response to prior comment 4. We are continuing to evaluate
this item
 and may have further comment.
 March 21, 2025
Page 2

Report of Independent Registered Public Accounting Firm, page F-2

3. Based on Amendment No. 3 to your Draft Registration Statement on Form
S-1
 submitted January 22, 2025, we note your auditor, FORVIS, LLP, audited
your
 financial statements as of and for the year ended December 31, 2023.
Given that your
 consolidated financial statements are now presented as of and for the
years ended
 December 31, 2024 and December 31, 2023, please revise your filing to
include an
 updated audit opinion that covers the two years ended December 31, 2024.
Refer to
 Item 2-02(a)(4) of Regulation S-X for guidance.
Consolidated Statements of Changes in Shareholders' Equity, page F-6

4. We note your presentation of an Other financing activities line
item. Please tell us,
 and revise your filing to describe, if material, what this amount
represents and discuss
 the related accounting treatment.
Consolidated Statements of Cash Flows, page F-7

5. We note your presentation of $5.6 million in Other financing activities
as a
 component of cash flows from investing activities, as well as your
presentation of
 $5.6 million in Other financing costs as a component of cash flows from
financing
 activities. Please explain if and how these amounts are related. Also
tell us how you
 determined that these items were investing and financing activities,
respectively, or
 revise your filing as necessary.
General

6. We note the statement on page 5 that, as of December 31, 2024, Citizens
Insurance
 had 936,182 policies, which appears to be a significant decline from a
year prior and
 the previously-disclosed 1.5 million policies. You continue to state you
believe
 Citizens will provide "continuous growth opportunities for years to
come." However,
 we also note the statement on page 16 that "[o]pportunities to acquire
large numbers
 of policies from Citizens meeting our strict underwriting criteria have
diminished in
 recent months." To the extent this is a material trend or uncertainty,
please revise
 MD&A as appropriate. Additionally, please revise where appropriate to
further clarify
 the process and trends related to "Citizens takeouts."
 Please contact Shannon Davis at 202-551-6687 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.
</TEXT>
</DOCUMENT>