Protective Life Corporation
Post Office Box 2606
Birmingham, AL 35202
205-268-1000
Steven G. Walker
Senior Vice President, Controller
and Chief Accounting Officer
205-268-6775
Fax: 205-268-3541
Toll Free 800-866-3555
Email: steve.walker@protective.com
August 28, 2009
Jim B. Rosenberg
Senior Assistant Chief Accountant
Securities and Exchange Commission
100 F Street, NW
Washington, DC 20549
RE: | Protective Life Corporation |
| Form 10-K for fiscal year ended December 31, 2008 |
File No. 001-11339 |
Dear Mr. Rosenberg:
On August 27, 2009, we had a telephone conversation with your staff related to our letter to you dated August 20, 2009. In that conversation, Ms. Tabatha Akins of your staff informed us of an additional comment the staff had related to Protective Life Corporation’s Annual Report on Form 10-K for the year ended December 31, 2008.
This letter provides our response to that comment. For your convenience, we have included the comment in bold type along with our response thereto.
Comment
We have read your response to our prior comment number three, but believe that the $20 million is material to net income (loss). Please revise your disclosure in your next periodic report to clarify the amount of realized/unrealized gains or losses that are material to net income (loss) related to assets transferred into Level 3 regardless of whether or not those gains or losses were recognized in the results of operations.
Response:
We will provide the requested information in our next periodic report.
* * * * *
In connection with our response, we acknowledge that:
· the Company is responsible for the adequacy and accuracy of the disclosure in the filings;
· staff comments or changes to disclosure in response to staff comments do not foreclose the Commission from taking any action with respect to the filing; and
· the Company may not assert staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.
We hope that this response satisfies your concerns. If you have any questions concerning this response, please do not hesitate to contact me at (205) 268-6775 or Charles Evers, Vice President, Corporate Accounting, at (205) 268-3596.
Sincerely, |
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/s/ Steven G. Walker |
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Steven G. Walker |
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Senior Vice President, Controller |
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cc: | Richard J. Bielen |
| Vice Chairman and Chief Financial Officer |
| Protective Life Corporation |
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