Via Facsimile and U.S. Mail
Mail Stop 6010
December 13, 2005
Mr. Kim D. Thorpe
Executive Vice President and Chief Financial Officer
FPIC Insurance Group, Inc.
225 Water Street, Suite 1400
Jacksonville, FL 32202
Re: FPIC Insurance Group, In.
Form 10-K for the Fiscal Year Ended December 31, 2004
Filed March 15, 2005
File No. 001-11983
Dear Mr. Thorpe:
We have reviewed your filing and have the following
comments.
We have limited our review of your filing to those issues we have
addressed in our comments. In our comments, we ask you to provide
us
with information so we may better understand your disclosure.
Please
be as detailed as necessary in your explanation. After reviewing
this information, we may raise additional comments.
Please understand that the purpose of our review process is
to
assist you in your compliance with the applicable disclosure
requirements and to enhance the overall disclosure in your filing.
We look forward to working with you in these respects. We welcome
any questions you may have about our comment or any other aspect
of
our review. Feel free to call us at the telephone numbers listed
at
the end of this letter.
Form 10-K for the Fiscal Year Ended December 31, 2004
Management`s Discussion and Analysis of Financial Condition and
Results of Operations for the year ended December 31, 2004
Liability for Losses and Loss Adjustment Expenses ("LAE"), page 17
1. We note your expanded disclosure in response to comment number
3
in our comment letter dated July 31, 2003. Please provide us the
following, in disclosure-type format:
* More detail regarding the specific actuarial techniques and
assumptions you use when estimating the liability for losses and
LAE.
Specifically address the factors that led management to determine
the
best estimate of loss reserves within your reserve range.
* Please provide quantified and narrative analyses of the impact
that
reasonably likely changes in one or more of your key assumptions
that
materially affect the reserve balance would have on reported
results,
financial position and liquidity. We note that you provide an
analysis around the total carried reserve balance but do not
provide
quantitative and narrative analyses around the key assumptions
that
affect the reserve balance.
* In addition, because IBNR reserve estimates are more imprecise,
please provide the amount of IBNR separately from case reserves
for
each line of business.
2. We refer to the last sentence on page 17 where you disclose the
fact that amounts that are settled for less than their
individually
estimated case reserves are used to offset other loss and LAE
reserve
components. Please explain to us in greater detail what this
means
and why this is appropriate under SFAS 60. It would helpful to
provide an example of this policy in your response.
Consolidated Results of Operations
Insurance Segment Results and Selected Other Information
Selected Direct Professional Liability Claims Information, page 23
3. We note from your table that the average paid loss with
indemnity
payment was $194,000 in 2004 and the total claims with indemnity
payments in 2004 were 350. This would appear to result in a total
net loss paid of $67,900,000, but your table shows total paid
losses
of $119,305,000. Please tell us, in disclosure-type format, the
difference between the $119,305,000 and the $67,900,000.
Contractual Obligations, Commitments and Off-Balance Sheet
Arrangements, page 37
4. It appears that scheduled interest payments on long-term debt
are
excluded from the contractual obligations table. Please explain
to
us, why interest payments are excluded. Please refer to section
IV
of Financial Reporting Release 72.
Notes to the Consolidated Financial Statements
Note 3. Investments, page F-16
5. Please tell us why you did not include the unrealized loss
position disclosure required by paragraph 21 of EITF 03-1.
Please respond to these comments within 10 business days or
tell us when you will provide us with a response. Please furnish
a
letter that keys your response to our comment and provide the
requested information. Detailed letters greatly facilitate our
review. Please file your letter on EDGAR under the form type
label
CORRESP.
We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filing to be certain that the
filing includes all information required under the Securities
Exchange Act of 1934 and that they have provided all information
investors require for an informed investment decision. Since the
company and its management are in possession of all facts relating
to
a company`s disclosure, they are responsible for the accuracy and
adequacy of the disclosures they have made.
In connection with responding to our comments, please
provide,
in your letter, a statement from the company acknowledging that:
* the company is responsible for the adequacy and accuracy of the
disclosure in the filing;
* 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.
In addition, please be advised that the Division of
Enforcement
has access to all information you provide to the staff of the
Division of Corporation Finance in our review of your filing or in
response to our comments on your filing.
You may contact Dana Hartz, Staff Accountant, at (202) 551-
3648
or Joseph Roesler, Senior Accountant, at (202) 551-3628 if you
have
questions regarding the comments. Please contact me at (202) 551-
3679 with any other questions.
Sincerely,
Jim B. Rosenberg
Senior Assistant Chief
Accountant
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Mr. Kim D. Thorpe
FPIC Insurance Group, Inc.
December 13, 2005
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