Infinity Property & Casualty (IPCC) CORRESP Correspondence with SEC

July 20, 2017

Jim B. Rosenberg

Senior Assistant Chief Accountant

Office of Healthcare and Insurance

Division of Corporate Finance

Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

RE: Infinity Property and Casualty Corporation ("the Company", "we" or "our")

Form 10-K for Fiscal Year Ended December 31, 2016

Filed February 28, 2017

FILE NO. 000-50167

Mr. Rosenberg,

This letter responds to your letter dated July 6, 2017, relating to comments of the staff of the Securities and Exchange Commission in connection with the above-referenced submission. Please note below the “SEC COMMENT” / “COMPANY RESPONSE” format.

1. SEC COMMENT: You disclose on page 23 under results of operations - 2016 compared to 2015 that you close your books on the last Friday of the month resulting in 2016 being a 53-week year. You also disclose that excluding the impact of this extra week, gross written premiums would have decreased 0.3% for the year. Please address the following:

• Tell us why you identify your fiscal year as the calendar year when you appear to close your books on the last Friday of each month.

• As you present your financial statements as of and for the periods ending December 31 but close your books on a different date, tell us:

◦ How you process material transactions or events occurring after your close but before the stated period end;

◦ The process you undertake to evaluate that your financial statements as of and for the period ending the last Friday of the month are not materially different from those that would be presented if you closed on the last day of the month;

◦ Why the presentation of a 53-week year in 2016 is not materially different from the calendar year; and

◦ Why you disclose herein that you evaluate events that occurred after December 31 for recognition or disclosure in your financial statements when you closed your books prior to December 31.

Also, as applicable, address the above bullets as they may relate to closing on the last Friday of the month in connection with your financial statements for quarterly periods included in Form 10-Q.

COMPANY RESPONSE:

Our fiscal year ends and we close our books on December 31 (and our quarters on March 31, June 30 and September 30). Balances included in the financial statements as of and for the periods ending December 31 (and for quarterly periods) are reflected as of that time period with the exception of premium and incurred loss activity. Our policy and claims systems close on the last Friday of each quarter. Adjustments are made to the balance sheet for losses paid or premiums received after the systems close. All other balances, transactions and events are stated, processed or evaluated as of and for the year ending December 31 (or appropriate quarterly period).

Our policy and claims systems operate on a 52-week year with 13-week quarters. The first two months of each calendar quarter are four weeks, followed by a five week month (March, June, September and December). A consequence of this calendar is that every five or six years, the Company reports a year that consists of 53 weeks. Our commentary notes the occurrence of the extra week when appropriate. This is consistent with other companies in our industry.

2. SEC COMMENT: Please tell us why you did not disaggregate liability coverage from property damage coverage in your Personal Auto and Commercial Vehicle claims development tables presented on page 47. Provide us the information that would be provided in separate tables for liability coverage and property damage coverage for each of these segments, if available. If not available, please provide us other quantitative and qualitative information to support aggregating these coverages in the same tables.

COMPANY RESPONSE:

In deciding the level at which to aggregate the data contained in the claims development tables the Company considered guidance in ASC 944-40-55-9A, 9B & 9C which states,

"Paragraphs 944-40-50-4A and 944-40-50-4H require an insurance entity to aggregate or disaggregate certain disclosures so that useful information is not obscured by either the inclusion of a large amount of insignificant detail or the aggregation of items that have significantly different characteristics to allow users to understand the amount, timing, and uncertainty of cash flows arising from contracts issued by insurance entities. Consequently, the extent to which an insurance entity’s information is aggregated or disaggregated for the purposes of those disclosures depends on the facts and circumstances that pertain to the characteristics of the liability for unpaid claims and claim adjustment expenses.

When selecting the type of category to use to aggregate or disaggregate disclosures, an insurance entity should consider how information about the insurance entity's liability for unpaid claims and claim adjustment expenses has been presented for other purposes, including all of the following:

a. Disclosures presented outside the financial statements (for example, in earnings releases, annual reports, statutory filings, or investor presentations)

b. Information regularly reviewed by the chief operating decision maker for evaluating financial performance

c. Other information that is similar to the types of information identified in (a) and (b) that is used by the insurance entity or user of the insurance entity's financial statements to evaluate the insurance entity's financial performance or make resource allocation decisions.

Examples of categories that might be appropriate include any of the following:

a. Type of coverage (for example, major product line)

b. Geography (for example, country or region)

c. Reportable segment as defined in Topic 280 on segment reporting

d. Market or type of customer (for example, personal or commercial lines of business)

e. Claim duration (for example, claims that have short settlement periods or claims that have long settlement periods)."

Information regularly reviewed by the Company's chief operating decision maker in evaluating financial performance as well as information presented outside the financial statements (for example, in the Company's quarterly supplemental investor package and investor presentations) is generally aggregated at the reportable segment level. As a result of this evaluation, the category selected for the claim development tables in the 10-K was reportable segment.

In determining the aggregation of liability and auto physical damage coverages, the Company concluded that disclosing physical damage separate from liability would not provide additional meaningful information to the reader as physical damage liabilities make up only 2.3% of the reserves at December 31, 2016.

We consider our disclosure consistent in all respects with ASC 944. As requested and solely for purposes of responding to this letter, we have provided separate tables for liability and auto physical damage coverages for Personal Auto and Commercial Vehicle below ($ in thousands, except severity):

	Personal Auto - Liability
Accident Year	Incurred losses and ALAE, net of reinsurance recoverable For the years ended December 31,																				IBNR & expected development on reported claims		Cumulative number of reported claims (1)	Severity (2)
	2007		2008		2009		2010		2011		2012		2013		2014		2015		2016		2016		2016	2016
2007	$	411,438	$	415,375	$	402,671	$	391,232	$	387,688	$	383,650	$	383,707	$	383,118	$	382,935	$	383,122	$	0	174,535	$	2,195
2008			370,950		365,395		348,841		344,914		342,775		343,137		341,566		340,998		340,785		4		151,691	2,247
2009					357,137		336,224		334,823		333,895		332,731		330,929		330,315		330,152		10		145,957	2,262
2010							386,452		400,888		404,963		406,602		404,872		406,279		404,807		16		170,117	2,379
2011									425,619		453,746		459,406		458,171		459,418		456,862		547		187,708	2,431
2012											521,603		540,012		540,572		541,696		538,233		5,550		216,346	2,462
2013													588,566		589,991		575,727		568,481		11,537		219,286	2,540
2014															569,899		572,955		561,861		21,271		213,188	2,536
2015																	583,490		582,177		39,910		215,596	2,515
2016																			596,021		174,184		199,863	2,111
																	Total		$	4,762,501

Accident Year		Cumulative paid losses and ALAE, net of reinsurance recoverable For the years ended December 31,
		2007		2008		2009		2010		2011		2012		2013		2014		2015		2016
2007		$	178,212	$	325,599	$	362,049	$	374,406	$	379,472	$	380,982	$	381,895	$	382,417	$	382,697	$	382,985
2008				164,563		284,203		317,660		331,628		336,700		339,436		340,305		340,495		340,649
2009						153,561		270,633		309,115		322,313		326,575		328,647		329,386		329,793
2010								182,160		332,625		374,717		391,125		397,254		401,597		403,976
2011										201,769		374,930		423,456		442,710		450,718		454,637
2012												246,387		444,359		501,466		521,104		529,190
2013														271,961		477,408		530,162		548,631
2014																270,893		470,297		521,257
2015																		282,064		488,501
2016																				290,108
		Total																		$	4,289,727
Outstanding liabilities for unpaid losses and ALAE prior to 2007, net of reinsurance recoverable																				1,230
Total outstanding liabilities for unpaid losses and ALAE, net of reinsurance recoverable																				$	474,003
(1)	The cumulative number of reported claims is measured by individual claimant at a coverage level.
(2)	Calculated severity amounts by accident year are based on inception-to-date incurred less IBNR and expected development dollars and reported claims. Note that older accident years are more developed than recent accident years.

	Personal Auto - Physical Damage
Accident Year	Incurred losses and ALAE, net of reinsurance recoverable For the years ended December 31,																				IBNR & expected development on reported claims		Cumulative number of reported claims (1)	Severity (2)
	2007		2008		2009		2010		2011		2012		2013		2014		2015		2016		2016		2016	2016
2007	$	188,649	$	197,180	$	194,147	$	194,293	$	194,466	$	194,536	$	194,722	$	194,681	$	194,642	$	194,655	$	0	108,552	$	1,793
2008			174,923		167,898		168,284		168,261		168,366		168,353		168,356		168,252		168,272		0		95,511	1,762
2009					140,256		137,104		137,949		137,972		138,983		141,594		142,685		143,208		0		84,871	1,687
2010							154,850		153,279		152,628		152,651		152,753		152,656		152,670		0		100,585	1,518
2011									183,016		179,265		178,993		179,399		179,090		179,043		31		120,196	1,489
2012											218,216		210,510		210,690		209,905		209,933		94		143,890	1,458
2013													216,472		215,469		213,701		213,888		199		145,498	1,469
2014															237,379		223,130		223,068		540		140,825	1,580
2015																	255,569		258,967		1,718		149,441	1,721
2016																			278,305		31,874		143,391	1,719
																	Total		$	2,022,007

Accident Year		Cumulative paid losses and ALAE, net of reinsurance recoverable For the years ended December 31,
		2007		2008		2009		2010		2011		2012		2013		2014		2015		2016
2007		$	180,847	$	197,112	$	194,471	$	194,386	$	194,609	$	194,618	$	194,761	$	194,730	$	194,686	$	194,655
2008				155,754		168,890		168,207		168,248		168,363		168,386		168,368		168,336		168,311
2009						131,593		137,902		138,063		138,150		138,878		141,385		142,403		143,282
2010								143,751		153,295		152,821		152,759		152,770		152,812		152,805
2011										172,598		179,315		179,066		179,209		179,274		179,224
2012												204,047		210,945		210,170		210,102		210,164
2013														208,503		214,631		214,026		214,139
2014																214,491		224,311		223,430
2015																		248,200		260,349
2016																				264,108
		Total																		$	2,010,467
Outstanding liabilities for unpaid losses and ALAE prior to 2007, net of reinsurance recoverable																				—
Total outstanding liabilities for unpaid losses and ALAE, net of reinsurance recoverable																				$	11,542
(1)	The cumulative number of reported claims is measured by individual claimant at a coverage level.
(2)	Calculated severity amounts by accident year are based on inception-to-date incurred less IBNR and expected development dollars and reported claims. Note that older accident years are more developed than recent accident years.

	Commercial Vehicle - Liability
Accident Year	Incurred losses and ALAE, net of reinsurance recoverable For the years ended December 31,																				IBNR & expected development on reported claims		Cumulative number of reported claims (1)	Severity (2)
	2007		2008		2009		2010		2011		2012		2013		2014		2015		2016		2016		2016	2016
2007	$	21,796	$	20,103	$	19,423	$	18,324	$	17,503	$	17,188	$	17,075	$	17,038	$	17,031	$	17,030	$	0	3,987	$	4,271
2008			20,258		17,047		14,845		14,778		14,218		13,939		13,865		13,890		13,890		0		4,100	3,388
2009					30,227		26,644		25,977		23,687		22,332		22,265		22,137		22,120		0		5,878	3,763
2010							34,557		32,609		29,343		28,020		26,881		27,332		26,949		44		7,273	3,699
2011									33,090		32,272		29,448		28,318		28,396		27,772		60		7,613	3,640
2012											42,396		38,781		38,144		38,279		37,722		706		8,680	4,265
2013													52,590		42,327		43,025		42,317		1,123		9,682	4,255
2014															54,452		52,320		53,700		2,073		11,375	4,539
2015																	67,731		70,252		3,155		13,694	4,900
2016																			79,025		27,595		13,621	3,776
																	Total		$	390,777

Accident Year		Cumulative paid losses and ALAE, net of reinsurance recoverable For the years ended December 31,
		2007		2008		2009		2010		2011		2012		2013		2014		2015		2016
2007		$	6,204	$	11,973	$	14,129	$	15,474	$	16,829	$	16,961	$	17,018	$	17,029	$	17,029	$	17,029
2008				5,471		10,367		12,124		13,224		13,780		13,841		13,842		13,888		13,888
2009						8,704		16,508		20,695		21,481		21,962		22,073		22,084		22,090
2010								10,156		19,375		23,600		25,678		26,177		26,774		26,838
2011										11,046		21,665		25,402		26,768		27,489		27,641
2012												14,608		27,182		33,381		35,505		36,469
2013														15,276		30,953		36,150		38,178
2014																18,518		36,152		44,168
2015																		24,840		49,828
2016																				27,539
		Total																		$	303,668
Outstanding liabilities for unpaid losses and ALAE prior to 2007, net of reinsurance recoverable																				33
Total outstanding liabilities for unpaid losses and ALAE, net of reinsurance recoverable																				$	87,141
(1)	The cumulative number of reported claims is measured by individual claimant at a coverage level.
(2)	Calculated severity amounts by accident year are based on inception-to-date incurred less IBNR and expected development dollars and reported claims. Note that older accident years are more developed than recent accident years.

	Commercial Vehicle - Physical Damage
Accident Year	Incurred losses and ALAE, net of reinsurance recoverable For the years ended December 31,																				IBNR & expected development on reported claims		Cumulative number of reported claims (1)	Severity (2)
	2007		2008		2009		2010		2011		2012		2013		2014		2015		2016		2016		2016	2016
2007	$	3,893	$	3,640	$	3,604	$	3,611	$	3,596	$	3,593	$	3,598	$	3,601	$	3,601	$	3,601	$	0	2,369	$	1,520
2008			4,199		4,140		4,115		4,115		4,102		4,106		4,108		4,106		4,106		0		2,495	1,646
2009					5,400		5,259		5,249		5,257		5,266		5,269		5,266		5,265		0		3,181	1,655
2010							6,765		6,540		6,538		6,519		6,515		6,513		6,511		0		3,929	1,657
2011									7,204		6,822		6,754		6,734		6,734		6,735		0		3,884	1,734
2012											8,690		8,169		8,140		8,126		8,110		0		4,438	1,827
2013													9,567		9,112		9,057		9,090		0		4,744	1,916
2014															11,272		10,984		10,982		56		5,360	2,038
2015																	14,117		14,062		117		6,349	2,196
2016																			16,512		1,897		6,688	2,185
																	Total		$	84,973

Accident Year		Cumulative paid losses and ALAE, net of reinsurance recoverable For the years ended December 31,
		2007		2008		2009		2010		2011		2012		2013		2014		2015		2016
2007		$	3,366	$	3,645	$	3,601	$	3,602	$	3,595	$	3,594	$	3,599	$	3,601	$	3,601	$	3,601
2008				3,623		4,122		4,100		4,107		4,106		4,106		4,106		4,106		4,106
2009						4,759		5,227		5,234		5,253		5,267		5,266		5,267		5,265
2010								5,953		6,528		6,520		6,513		6,513		6,512		6,511
2011										6,351		6,762		6,724		6,727		6,734		6,734
2012												7,665		8,140		8,120		8,118		8,109
2013														8,557		9,085		9,049		9,092
2014																10,110		11,010		10,963
2015																		13,079		14,104
2016																				14,929
		Total																		$	83,414
Outstanding liabilities for unpaid losses and ALAE prior to 2007, net of reinsurance recoverable																				—
Total outstanding liabilities for unpaid losses and ALAE, net of reinsurance recoverable																				$	1,559
(1)	The cumulative number of reported claims is measured by individual claimant at a coverage level.
(2)	Calculated severity amounts by accident year are based on inception-to-date incurred less IBNR and expected development dollars and reported claims. Note that older accident years are more developed than recent accident years.

	Average annual payout of losses and LAE, net of reinsurance
	Year 1		Year 2		Year 3		Year 4		Year 5		Year 6		Year 7		Year 8		Year 9		Year 10
Personal Auto - Liability	46.9	%	36.2	%	10.0	%	3.8	%	1.6	%	0.8	%	0.3	%	0.1	%	0.1	%	0.0	%
Personal Auto - Physical Damage	94.9	%	5.1	%	(0.5	)%	(0.1	)%	0.0	%	0.2	%	0.1	%	0.1	%	0.0	%	0.0	%
Commercial Vehicle - Liability	37.2	%	35.3	%	14.8	%	6.8	%	4.2	%	1.2	%	0.2	%	0.2	%	0.0	%	0.0	%
Commercial Vehicle - Physical Damage	92.2	%	8.1	%	(0.4	)%	0.1	%	0.0	%	0.0	%	0.0	%	0.0	%	0.0	%	0.0	%

3. SEC COMMENT: You disclose that certain claims and legal actions have been brought against you for which you have accrued no loss and for which an estimate of a possible range of loss cannot be made. You go on to say that losses incurred because of these cases could have a material adverse impact on net earnings in a given period. Please tell us the nature of these loss contingencies and your consideration for disclosing their nature in your filings under ASC 450-20-50-4a.

COMPANY RESPONSE:

As prescribed under ASC 450-20, we have disclosed in Note 13 the nature of possible (and not probable) loss contingencies: namely, extra-contractual claims (bad faith lawsuits) and class actions.  We also indicate, as required under ASC 450-20, that an estimate of loss or range of loss cannot be made and that, as a consequence, no loss has been accrued.   Consequently, we consider our disclosure consistent in all respects with ASC 450-20.

Please contact me if you have any further questions or comments.

Sincerely,

/s/ ROBERT H. BATEMAN

Robert H. Bateman

Executive Vice President, Chief Financial Officer and Treasurer