SecProbe.io

CORRESP
 1
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 CORRESP

 Slide Insurance Holdings, Inc.
 4221 W. Boy Scout Blvd. Suite 200
 Tampa, Florida 36607 June 13, 2025
 U.S. Securities and Exchange Commission Division of
Corporation Finance Office of Finance 100 F Street, N.E.,
Room 4415 Washington, D.C. 20549-4631

 Attn:

 Shannon Davis Lory Empie
 Aisha Adegbuyi James Lopez

 Re:
 Slide Insurance Holdings, Inc.

  
 Acceleration Request for Registration Statement on Form S-1

  
 Registration File No. 333-287556
 Ladies and Gentlemen: In accordance with Rule
461 of the General Rules and Regulations under the Securities Act of 1933, as amended, Slide Insurance Holdings, Inc. (the “Company”) hereby requests that the effective date of the above-referenced Registration Statement be accelerated so
that it becomes effective at 4:00 p.m. Eastern Time on June 17, 2025, or as soon thereafter as practicable, or at such other time thereafter as the Company or its outside counsel, Davis Polk & Wardwell LLP, may request by telephone to
the staff of the Securities and Exchange Commission. Once the Registration Statement has been declared effective, please orally confirm that event with our counsel, Davis Polk & Wardwell, LLP, by calling Richard D. Truesdell, Jr. at (212) 450-4674 or Joseph D. Payne at (212) 450-3378. We understand
that the staff of the Securities and Exchange Commission will consider this request as confirmation by the Company that it is aware of its responsibilities under the federal securities laws as they relate to the issuance of the securities covered by
the Registration Statement. If you have any questions regarding the foregoing, please contact Richard D. Truesdell, Jr. or Joseph S. Payne of Davis Polk & Wardwell at the numbers set forth above.
 Thank you for your assistance in this matter.

 Very truly yours,
 Slide Insurance Holdings, Inc.

 By:

 /s/ Jesse Schalk

 Name:

 Jesse Schalk

 Title:

 Chief Financial Officer

 Cc:
 Bruce Lucas, Slide Insurance Holdings, Inc.
 Richard D. Truesdell, Jr., Davis Polk & Wardwell LLP
 Joseph S. Payne, Davis Polk & Wardwell LLP
 Dwight S. Yoo, Skadden, Arps, Slate, Meagher & Flom LLP

CORRESP
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 CORRESP

 BARCLAYS CAPITAL INC.
 745 7 TH AVENUE
 NEW YORK, NEW YORK 10019

 MORGAN STANLEY & CO. LLC
 1585 BROADWAY NEW YORK, NEW YORK
10036
 June 13, 2025 VIA
EDGAR U.S. Securities and Exchange Commission Division
of Corporation Finance 100 F Street, N.E. Washington, D.C.
20549-6010

 Attention:

 Shannon Davis

 Lory Empie

 Aisha Adegbuyi

 James Lopez

 Re:
 Slide Insurance Holdings, Inc.
 Registration Statement on Form S-1, as amended (File
 No. 333-287556) Request for Acceleration of Effective Date
 Ladies and Gentlemen: We refer to the
Registration Statement on Form S-1 (File No. 333-287556) (as amended, the “Registration Statement”), of Slide Insurance Holdings, Inc. (the
“Company”). In accordance with Rule 461 under the Securities Act of 1933, as amended (the “Act”), we, as
representatives of the several underwriters (the “Underwriters”), hereby respectfully request that the Registration Statement become effective as of 4:00 p.m., Eastern Time, on June 17, 2025, or as soon as practicable thereafter, or
at such other time as the Company or its legal counsel may request by telephone to the staff of the Division of Corporation Finance of the U.S. Securities and Exchange Commission.
 Pursuant to Rule 460 under the Act, we, as representatives of the Underwriters, wish to advise you that we will take reasonable steps to
secure adequate distribution of the Company’s preliminary prospectus, dated June 9, 2025, to underwriters, dealers, institutions and others prior to the requested effective time of the Registration Statement.
 We, as representatives of the Underwriters, have complied and will comply, and we have been informed by the participating Underwriters that
they have complied and will comply, with the requirements of Rule 15c2-8 under the Securities Exchange Act of 1934, as amended.
 [ Signature Page Follows ]

 Sincerely,

 BARCLAYS CAPITAL INC.

 MORGAN STANLEY & CO. LLC

 As representatives of the several Underwriters

 BARCLAYS CAPITAL INC.

 By:

 /s/ Warren Fixmer

 Name: Warren Fixmer

 Title: Managing Director

 MORGAN STANLEY & CO. LLC

 By:

 /s/ Jyri Wilska

 Name: Jyri Wilska

 Title: Managing Director

CORRESP
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 CORRESP

 Richard D. Truesdell, Jr. +1 212 450 4674
 richard.truesdell@davispolk.com

 Davis Polk & Wardwell LLP
 450 Lexington Avenue New York, NY 10017
 davispolk.com

 CONFIDENTIAL
 May 23, 2025

 Re:
 Slide Insurance Holdings, Inc.
 Draft Registration Statement on Form S-1
 Submitted on June 18, 2024
 CIK No. 0001886428 U.S. Securities and
Exchange Commission Division of Corporation Finance Office
of Finance 100 F Street, N.E., Room 4415 Washington, DC
20549-4631

 Att’n:
   Shannon Davis
 Lory Empie Aisha Adegbuyi
 James Lopez Ladies and Gentlemen:
 On behalf of our client, Slide Insurance Holdings, Inc., a Delaware corporation (the “ Company ” or “ Slide ”), we are responding
to the comments from the Staff (the “ Staff ”) of the Securities and Exchange Commission (the “ Commission ”) relating to the Company’s confidential draft Registration Statement on Form S-1 (CIK No. 0001886428) (the “ Registration Statement ”) contained in the Staff’s letter dated May 9, 2025. The Company has revised the Registration Statement and is publicly filing
via EDGAR a further amended Registration Statement together with this response letter. Set forth below are the Company’s responses to the
Staff’s comments. For convenience, the Staff’s comments are repeated below in italics, followed by the Company’s responses to the comments. Where applicable, we have included page numbers to refer to the location in the Registration
Statement where revised language addressing a particular comment appears. Capitalized terms used but not defined herein are used as defined in the Registration Statement.
 Draft Registration Statement on Form S-1
 Management’s Discussion and Analysis of Financial Condition and Results of Operations Revenue

 1.
 We note that the significant increase in premiums written and earned since 2023 have been primarily
attributable to assumptions of policies from Citizens Property Insurance Corporation (“Citizens”). Please revise, here or where appropriate, to clearly describe your arrangement with Citizens and the process for assuming policies from
Citizens’ take-out program. For example, and without limitation, please address:

 •

 Summarize the typical terms of the timing and process surrounding how and when you may assume these
policies,

 •

 Discuss any policies and procedures your Board of Directors and management have established surrounding the
assumption of policies from Citizens,

 •

 Highlight the general criteria you consider when selecting which policies to assume,

 CONFIDENTIAL

 •

 Disclose when and under what conditions (if any) policyholders are allowed to return to Citizens after being
assumed by Slide,

 •

 Clearly state at what point you assume the insurance risks related to these assumed policies and become
responsible for the associated losses,

 •

 Discuss your general expectations to continue assuming policies from Citizens in the future, and

 •

 Discuss reasons for potential differences in loss development associated with the policies assumed from
Citizens and your historical and current loss development experience. Response: The Company respectfully
acknowledges the Staff’s comment and has revised its disclosure on pages 22, 23, 76, and 107-121 of the Registration Statement.

 2.
 Please refer to prior comment 2. We continue to evaluate your response and may have further comments.
 Response: The Company acknowledges that the Staff continues to evaluate the Company’s response to prior
comment 2. *  *  * We hope the
foregoing answers are responsive to your comments. Please do not hesitate to contact me at (212) 450-4674 ( richard.truesdell@davispolk.com ) or Joseph S. Payne at (212)
 450-3378 ( joseph.payne@davispolk.com ) if you have any questions regarding the foregoing or if we may provide any additional information.
 Very truly yours, /s/ Richard D. Truesdell, Jr.

 cc:
 Bruce Lucas, Slide Insurance Holdings, Inc.
 Jesse Schalk, Slide Insurance Holdings, Inc.
 Joseph S. Payne, Davis Polk & Wardwell LLP
 Dwight S. Yoo, Skadden, Arps, Slate, Meagher & Flom LLP

 May 23, 2025

 2

<DOCUMENT>
<TYPE>TEXT-EXTRACT
<SEQUENCE>2
<FILENAME>filename2.txt
<TEXT>
 May 9, 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. 5 to Draft Registration Statement on Form S-1
 Submitted April 25, 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 March 21,
2025 letter.

Amendment No. 5 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 that the significant increase in premiums written and earned
since 2023 have
 been primarily attributable to assumptions of policies from Citizens
Property
 Insurance Corporation ( Citizens ). Please revise, here or where
appropriate, to
 clearly describe your arrangement with Citizens and the process for
assuming policies
 from Citizens take-out program. For example, and without limitation,
please address:

 Summarize the typical terms of the timing and process surrounding
how and when
 you may assume these policies,
 Discuss any policies and procedures your Board of Directors and
management
 May 9, 2025
Page 2

 have established surrounding the assumption of policies from
Citizens,
 Highlight the general criteria you consider when selecting which
policies to
 assume,
 Disclose when and under what conditions (if any) policyholders are
allowed to
 return to Citizens after being assumed by Slide,
 Clearly state at what point you assume the insurance risks related
to these
 assumed policies and become responsible for the associated losses,
 Discuss your general expectations to continue assuming policies
from Citizens in
 the future, and
 Discuss reasons for potential differences in loss development
associated with the
 policies assumed from Citizens and your historical and current loss
development
 experience.
2. Please refer to prior comment 2. We continue to evaluate your response
and may have
 further comments.
 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>

<DOCUMENT>
<TYPE>TEXT-EXTRACT
<SEQUENCE>2
<FILENAME>filename2.txt
<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>

February 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. 3 to Draft Registration Statement on Form S-1
Submitted January 22, 2025
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 September 20, 2024 letter.
Amendment No. 3 to Draft Registration Statement on Form S-1
Prospectus Summary, page 1
1.We note your response to prior comment 1, as well as your revised disclosure on page
6, which indicates that you intend to close the acquisition of Pawtucket Insurance
Company ("PIC") prior to the consummation of your securities offering. Please tell
us your consideration of including pro forma financial statements, according to the
guidance in Rule 11-01 of Regulation S-X, and financial statements of PIC, according
to the guidance in Rule 3-05 of Regulation S-X, in your filing.
We note the statement on page 3 that, "[w]ith the exception of hurricane claims,"
you manage all aspects of the claims process in-house. Please revise to indicate the 2.

February 21, 2025
Page 2
approximate percentage of claims that relate to hurricanes.
3.Please revise to explain how you use the term "commercial residential" in describing
your business.
Management's Discussion and Analysis of Financial Condition and Results of Operations
Revenue, page 78
4.We note your disclosures on pages 78 and 82 which describe your assumed policies
from Citizens and your acquired policies from St. Johns Insurance Company, United
Property & Casualty Insurance Company, and Truck Insurance Exchange. Please tell
us how you considered whether historical financial information about the acquired
and assumed blocks of insurance policies is necessary for investors to understand your
future operations. Please include, but do not limit your analysis to, your consideration
of the guidance in Rule 11-01(d) of Regulation S-X. If you determine that historical
financial information about the acquired and assumed blocks of insurance policies is
necessary, please describe the nature of such information that you believe would
provide an understanding of your future operations.
5.Please disclose, within the tables and related discussion on pages 78 and 82 or
elsewhere in the filing, the rate of renewals on your acquired and assumed policies for
each reporting period presented. Please provide these renewal rates disaggregated by
source of policy (e.g., Citizens Policies, UPC Policies, Organic Policies, etc.).
6.We note your disclosure that the increase in net premiums written in the nine months
ended September 30, 2024, was, among other reasons, a result of the acquisition and
subsequent renewals of Florida homeowners' policies from Truck Insurance
Exchange, a subsidiary of Farmers Insurance Company, Inc. ("Farmers"). Please tell
us why the Farmers Policies are reflected in the "New policies written" row in your
table on page 78, when you describe these as acquired policies. Please revise your
disclosure as needed.
Expenses, page 79
7.We note your disclosure on page 83, which identifies and quantifies catastrophe losses
included in your amount of losses and loss adjustment expenses incurred, net, for the
years ended December 31, 2023 and 2022. Please revise your disclosure on page 79,
or elsewhere in the filing, to provide a similar quantification and discussion of
catastrophe losses recognized in the nine months ended September 30, 2024 and 2023,
as well as a discussion of the timing and specific events driving the majority of
catastrophe losses recognized during these periods.
Consolidated Balance Sheets, page F-2
8.Please revise your presentation on the face of the balance sheet, of both the annual and
interim financial statements, to include the number of issued and outstanding shares of
common stock. Please refer to Rule 5-02 of Regulation S-X.

February 21, 2025
Page 3
Notes to Consolidated Financial Statements for the nine months ended September 30, 2024
and 2023
1. Nature of Business and Significant Accounting Policies, page F-7
9.We note your disclosure on page F-8 of the number of issued and outstanding shares
of common stock and preferred stock as of December 31, 2023 and 2022. Please
revise your filing to provide the number of issued and outstanding shares as of the
relevant balance sheet dates in your interim financial statements.
Notes to Consolidated Financial Statements for the years ended December 31, 2023 and 2022
1. Nature of Business and Significant Accounting Policies, page F-28
10.We note your response to prior comment 2 and reissue. We note that your response
describes the accounting for the policies assumed from Citizens as reinsurance.
However, we also note that you have certain acquired policies, such as those from St.
Johns Insurance Company, United Property & Casualty Insurance Company ("UPC"),
and Farmers. Please describe your accounting policy for the acquired insurance
policies, including, for example:
•whether the policies are acquired on a prospective basis, similar to the policies
assumed from Citizens;
•any assets or liabilities that you initially recognize at acquisition, and how they
are measured;
•whether consideration is exchanged for the acquired policies; and
•how you account for any difference that may exist between the fair value of the
acquired policies and the amount that you initially measure and recognize on your
financial statements at acquisition.
Please revise your disclosure as appropriate and tell us the authoritative guidance
upon which you relied.
25. Variable Interest Entities, page F-62
11.We note your disclosure of $107.2 million and $51.9 million at December 31, 2023
and 2022, respectively, of restricted cash and cash equivalents held by your
consolidated variable interest entity ("VIE"), which "can be used only to settle
specific reinsurance obligations of the VIE as of the dates presented." Please revise
your presentation on the face of the balance sheet to separately present, and clearly
label, these amounts. Please refer to ASC 810-10-45-25.
General
12.We note revised disclosure regarding the Substantial Ownership Requirement. Please
revise such references to include the pertinent quantitative threshold(s). Additionally,
please revise to identify the document(s) and specific provision(s) establishing the
requirement.
            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

February 21, 2025
Page 4
with any other questions.
Sincerely,
Division of Corporation Finance
Office of Finance
cc:Richard D. Truesdell, Jr., Esq.

September 24, 2024
Bruce Lucas
Chief Executive Officer
Slide Insurance Holdings, Inc.
4221 W. Boy Scout Blvd.
Tampa, FL 33607
Re:Slide Insurance Holdings, Inc.
Amendment No. 2 to Draft Registration Statement on Form S-1
Submitted September 4, 2024
CIK No. 0001886428
Dear Bruce Lucas:
            We have reviewed your amended draft registration statement and have the following
comment.
            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
August 22, 2024, letter.
General
1.We note your response to prior comment 2 that you are “under contract” to acquire
Pawtucket Insurance Company from a subsidiary of Heritage Insurance Holdings, Inc. We
also note a PR Newswire article, “Heritage Announces Strategic InsurTech Partnership
with Slide,” dated November 26, 2021, which discusses what appears to be a similar
transaction, including a 6% ownership as well as transfers of Pawtucket and various
licenses and software. With a view towards clarifying disclosure in the registration
statement regarding the intended transaction and the company's plans to grow
geographically in the Atlantic coastal specialty markets, please explain to us the terms of
the contract, as referenced.

September 24, 2024
Page 2
            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.

September 20, 2024
Bruce Lucas
Chief Executive Officer
Slide Insurance Holdings, Inc.
4221 W. Boy Scout Blvd.
Tampa, FL 33607
Re:Slide Insurance Holdings, Inc.
Amendment No. 2 to Draft Registration Statement on Form S-1
Submitted September 4, 2024
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 August 22, 2024, letter.
Amendment No. 2 to Draft Registration Statement on Form S-1
Notes to Consolidated Financial Statements
1. Nature of Business and Significant Accounting Policies, page F-28
1.We note your response to prior comment 8, which explains that your policy
acquisitions generally do not meet the definition of a business combination. Further, you
note that the acquired policies are subsequently accounted for following the general
revenue recognition policy disclosed on page F-35 of the amended draft registration
statement. Please tell us how you initially recognize and measure the acquired policies,
such as an explanation of any contractual assets or liabilities that are recognized as part of
the acquired policies and how they are measured. Please revise your disclosure as
appropriate and tell us the authoritative guidance upon which you relied.

September 20, 2024
Page 2
7. Fair Value of Financial Assets and Liabilities, page F-43
2.We note your tabular disclosure on page F-44, which includes an interest rate swap
liability classified as a Level 3 fair value measurement as of December 31, 2023. We also
note your disclosure on page F-45 that the Company does not have any Level 3 assets or
liabilities. Please revise your disclosure, here as well as in the relevant note to the
financial statements for the six months ended June 30, 2024, to consistently describe your
Level 3 assets and liabilities.
            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.

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.

July 16, 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 June 18, 2024
CIK No. 0001886428
Dear Bruce Lucas:
            We have reviewed your 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.
Draft Registration Statement on Form S-1
Prospectus Summary, page 1
1.We note your disclosure of a “consolidated net-attritional loss ratio” on page 4. Please
revise to describe what this loss ratio represents and how it is calculated.
2.Please revise to define and explain, for the average investor, terms such as Managing
General Agency, coastal specialty zone and Direct to Consumer.
3.Please provide a basis for the statement that you have "a significant technological
advantage that allows [you] to assess, manage and price risk for individual and bulk
policy acquisitions." We note you do not address this significant technological advantage
on page 95 or in a discussion of your competitive position.
4.Please revise to clearly explain your geographic concentration, including the extent to
which premiums are concentrated on the coasts of South Carolina and Florida.

July 16, 2024
Page 2
Expanding our presence in admitted and E&S coastal specialty markets, page 5
5.We note your disclosure that you seek to expand your presence in E&S coastal specialty
markets. Revise your disclosure to explain why this market is termed "non-admitted." In
this regard, it is unclear if Slide Insurance Holdings is not admitted or enrolled with the
insurance commission of the states where you do, or intend to do, business. Further clarify
the risky nature of the areas where you do business, which are "avoided" by competitors.
For example, clarify, if true, that most insurers cannot perform the actuarial risk
assessment necessary for approval by the relevant state insurance commission. Your
revised disclosure should clearly explain the risks of writing insurance in this space,
including, if true, the reliance on substantially less data to price the premiums.
Our Organizational Structure, page 9
6.Please also include an organizational chart depicting your organizational structure and
ownership after the initial public offering.
Summary Consolidated Financial and Other Data, page 12
7.Your presentation of combined ratio, excluding catastrophic losses and prior year claims
development appears to represent a non-GAAP financial measure given that it excludes
amounts that are included in the combined ratio, the most directly comparable measure
calculated and presented in accordance with GAAP. Please revise your filing to clearly
label and identify this ratio as a non-GAAP financial measure and provide all of the
relevant disclosures required by Item 10(e)(1) of Regulation S-K.
8.We note your disclosure of the “net acquisition expense ratio,” which is the ratio of net
acquisition expenses to net premiums earned. Please tell us and revise to describe,
quantitatively and qualitatively, what comprises your net acquisition expenses.
Additionally, please tell us how you determined that the net acquisition expense ratio does
not constitute a non-GAAP financial measure. Refer to Rule 101(a) of Regulation G and
Question 100.05 of the Division of Corporation Finance's C&DI on Non-GAAP Financial
Measures. Please revise your filing as applicable.
Risk Factors, page 15
9.We note your organizational structure depicted on page 9, which explains that Slide
Specialty Insurance Inc. is under contract to be purchased but has not yet closed due to
pending regulatory approval. We also note your disclosure on page 15 that “all references
in this subsection to the “Company,” “we,” “us” or “our” refer to the business of Slide
Insurance Holdings, Inc., its subsidiaries, Slide Insurance Company and Slide Specialty
Insurance Inc. (each, a “Carrier”).” Please revise your definition to exclude Slide
Specialty Insurance Inc., which has not yet been acquired.
10.In this regard, please file the MGA agreement with your "primary customer," as
referenced on page 19 or advise us why it is not a material agreement under Item
601(b)(10) of Regulation S-K.

July 16, 2024
Page 3
Our expansion within the United States will subject us to additional costs and risks and our plans
may not be successful, page 20
11.We note your disclosure, in this risk factor, stating that "[a]s of December 31, 2023, the
Carriers are legally permitted to write insurance in two states of the United States, Florida
and South Carolina." We also note your statement on page 2 stating that you "write
several homeowners’ and condominium owners’ products in coastal specialty markets,
most notably in Florida and South Carolina." Please clarify on page 2, and where
appropriate, that you are currently only writing insurance in these two states or advise.
Intense competition in the segments of the insurance industry in which we operate, page 21
12.We note your disclosure that your competitors include companies such as "Universal
Property and Casualty, Progressive and People’s Trust in the State of Florida and
companies such as Allstate, Farmers, Progressive, Liberty Mutual, State Farm and
Travelers in states [you] may seek to expand into." Please disclose the criteria you used to
identify these companies as your competitors.
13.Revise this risk factor to discuss the extent to which the ability to compete in your market
is dependent on existing relationships.
Reinsurance may be unavailable at current levels and prices, page 22
14.We note your disclosure on page 23 that "[a]ll of [y]our rated reinsurers have an AM Best
rating of A- or better." Please revise this risk to disclose the possible risks that could result
from a fall in those ratings.
We rely on the experience and expertise of our Co-Founders, senior management team, highly
specialized insurance experts, page 28
15.We note the statement that you rely on "a small number of highly specialized insurance
experts." If material, revise to identify the number of such experts and lines of business to
provide context for the risk factor. Additionally, revise your Business section or where
appropriate to discuss the steps taken to mitigate the risks described here.
Performance of our investment portfolio is subject to a variety of investment risks, page 32
16.We note your risk factor which discloses that “[i]n recent years, interest rates have been at
or near historic lows. A protracted low interest rate environment would continue to place
pressure on our net investment income, particularly as it relates to fixed income securities
and short-term investments, which, in turn, may adversely affect our operating results.”
Please revise your disclosure to also discuss the more recent rising interest rate
environment.
The insurance business, including the market for homeowners insurance, is historically cyclical in
nature, page 45
17.Please clarify in this risk factor, and its subheading, where the insurance industry
currently is in terms of its cyclical nature so that investors may assess the risk.

July 16, 2024
Page 4
We operate in a highly regulated environment, page 46
18.We note the statement that two senior officers at your MGA subsidiary and your CFO
were officers of an insurance company that became insolvent. You also state that,
"[r]ecently, the FLOIR has issued letters to many insurance carriers in Florida, including
Slide Insurance Company, asking for additional information on compliance with the
statute." Please revise to provide additional context, including the expected timing for
resolution of the matters, and clarify the nature and extent of how adverse resolutions
could impact your business.
Management's Discussion and Analysis of Financial Condition and Results of Operations, page
71
19.Please revise your Management’s Discussion and Analysis of Financial Condition and
Results of Operations section to discuss your financial condition and changes in financial
condition for each of the periods presented as required by Item 303 of Regulation S-K.
Refer to SEC Release Nos. 33-6835 and 33-8350.
Revenue, page 75
20.We note you attribute the increase in net premium written as primarily a result of
assumptions of policies from Citizens, the acquisition and subsequent renewals of United
Property & Casualty Insurance Company policies, and new policies written. Additionally
we note you identify policies-in-force and average premium per policy as key
performance indicators on page 14. Please revise, here or where appropriate, to address
the following:
•disclose and discuss the number of polices written by policy acquisition channel (i.e.
assumptions, acquisitions and renewals, independent agents and direct-to-consumer)
for the periods presented;
•additionally or together, include a roll-forward of policies-in-force by acquisition
channel for the periods presented; and
•disclose and discuss period over period changes in average premium per policy.
Expenses, page 76
21.Please revise to address the following items:
•quantify and discuss period over period catastrophic losses recognized within the
financial statements, and
•identify the timing and specific events driving the majority of catastrophic losses
recognized within the periods presented within financial statements.
22.Please revise to disclose quantitative detail of the costs presented in the “General and
administrative expenses” line item for each period presented.
Quantitative and Qualitative Disclosures about Market Risk
Interest Rate Risk, page 81
We note that your sensitivity analysis for your interest rate risk exposure assumes a 100
basis point increase/decrease in interest rates. Please tell us how you determined that 100
basis points was the appropriate measurement point for the possible impact of an increase 23.

July 16, 2024
Page 5
or decrease in interest rates, particularly given the changes in interest rates experienced in
the past 12 months.
Critical Accounting Policies and Estimates, page 82
24.We note your disclosure on page 85 that you currently classify your investments in
mortgage loans as held to maturity and report them at amortized cost. Please revise your
filing to provide additional information about these mortgage loans in your notes to
consolidated financial statements, including the disclosures required by ASC 326-20.
Business, page 87
25.Please disclose whether you have any dependence on key products or product lines. If so,
please revise your Business, Risk Factors and MD&A sections accordingly.
Reinsurance, page 91
26.We note that you utilize catastrophe bonds as a method of reinsurance. Please tell us
whether you are the issuer of the catastrophe bonds and summarize how you accounted
for the issuance of these catastrophe bonds. Please also tell us the relevant accounting
guidance considered.
Ratings, page 96
27.We note your risk factor disclosure on page 19 that you do not have a rating from AM
Best Company. Revise your disclosure on page 96 to include a similar discussion.
Government Regulation, page 96
28.Please revise your disclosure here to clarify the anticipated timeframe for being subject to
the additional minimums and restrictions under the consent with FLOIR.
29.We note some state actions to limit rising interest rates and decisions by insurers to leave
or discontinue policies in certain states due to regulatory restrictions or frequency of
catastrophic and other events. Please revise your Government Regulation disclosure, or
where appropriate, to further describe the economic and regulatory environment,
especially as they relate to Florida and South Carolina and their coasts.
Anti-Takeover Effects of Some Provisions, page 121
30.We note your disclosure that some provisions of your certificate of incorporation and
bylaws could make the removal of your incumbent officers and directors more difficult.
Please revise this section to specify which provisions you are referring to or advise.
Forum Selection, page 121
We note that your forum selection provision identifies a state court or federal court
located within the State of Delaware as the exclusive forum for certain litigation,
including any “derivative action.” We also note your risk factor disclosure on page 62,
discussing the enforceability of this provision in relation to the Exchange Act. Please
revise your disclosure on page 121 to include a similar discussion. Please ensure that the
exclusive forum provision in your governing documents states clearly, if true, that the
provision does not apply to actions arising under the Exchange Act and also revise, where 31.

July 16, 2024
Page 6
appropriate, to state that investors cannot waive compliance with the federal securities
laws and the rules and regulations thereunder.
Consolidated Statements of Operations, page F-5
32.Please tell us how you considered, and your basis for, concluding not to present
catastrophic losses as a separate line item within your Consolidated Statements of
Operations. Cite the authoritative guidance upon which you relied.
Notes to Consolidated Financial Statements
1. Nature of Business and Significant Accounting Policies, page F-9
33.We note your disclosure on page F-10 that you have assumed insurance policies from
Citizens Property Insurance Corporation (“Citizens”), as well as your disclosures
throughout the filing that policies assumed from Citizens and other insurance entities have
contributed to your growth. Please revise your disclosure to summarize your initial
recognition and measurement of assumed policies. Please tell us the authoritative
guidance upon which you relied.
34.We note your disclosure on page F-15 that the “if-converted” method is used in
calculating diluted EPS. Please tell us how you determined that the if-converted method is
appropriate to apply in determining the dilutive effect of your common stock share option
awards. Please refer to ASC 260-10-45-28A.
Notes to Consolidated Financial Statements
6. Fixed-Maturity Securities Available-For-Sale, page F-22
35.We note that your net investment income was $20.9 million and $2.4 million in 2023 and
2022, respectively, which, as disclosed on page F-24, excludes realized gains. We also
note your disclosure on pg. F-27 that realized gains and losses are reflected in “net
realized investment gains (losses) on the consolidated statements of income” although
such a line item is not presented in the income statement. Please revise your filing to
disclose the amount of any realized gains and losses on investment securities for the
periods presented and to clarify where such realized gains and losses are presented in your
financial statements.
Notes to Consolidated Financial Statements
10. Loss and Loss Adjustment Expenses, page F-28
36.Please revise to disclose a description of your methodology for calculating cumulative
claim frequency information. Refer to ASC 944-40-50-4F.
37.We note your disclosure on page F-30 that your tabular disclosure about incurred and paid
losses and reserve development, as well as cumulative claim frequency and the total
incurred-but-not-reported liabilities plus expected development on reported claims, is
“supplementary and unaudited information.” Please tell us how you determined that this
information should be considered supplementary and unaudited, including for the most
recent reporting period. Please refer to ASC 944-40-50-4B and revise as appro