United States securities and exchange commission logo
October 4, 2021
Kenneth A. Brause
Chief Financial Officer
Burford Capital Limited
Oak House
Hirzel Street
St. Peter Port GY1 2NP
Guernsey
Re: Burford Capital
Limited
Form 20-F for the
Fiscal Year Ended December 31, 2020
Filed March 24,
2021
Form 6-K Dated
September 9, 2021
Filed September 9,
2021
File No. 001-39511
Dear Mr. Brause:
We have reviewed your August 20, 2021 response to our comment
letter and have the
following comments. In some of our comments, we may ask you to provide
us with information
so we may better understand your disclosure.
Please respond to these comments within 10 business days by
providing the requested
information or advise us as soon as possible when you will respond. If
you do not believe our
comments apply to your facts and circumstances, please tell us why in
your response.
After reviewing your
response to these comments, we may have additional comments.
Form 6-K Filed September 9, 2021
Exhibit 99.1: Burford Capital Limited Half-Year Report for the period
ended June 30, 2021
Consolidated operating results
Six months ended June 30, 2021, compared to six months ended June 30,
2020
Operating Expenses, page 17
1. At the bottom of page
17 carrying over onto page 18 you discuss a $45 million additional
accrual in the first
half of 2021 related to a change in accounting estimate related to
certain "carry plans."
You indicate that historically you recognized carry plan expense
only upon realizations
of the related capital provision assets and not on the basis of
Kenneth A. Brause
Burford Capital Limited
October 4, 2021
Page 2
unrealized gains. Please tell us why this charge in 2021 is the result
of a change in
estimate and reference for us the authoritative literature you rely
upon to support your
position. In your response, address the following:
Tell us how your prior accounting complied with the guidance in
IAS 19.
Tell us your consideration of the guidance in IAS 19.24.
Tell us how your current accounting complies with the guidance in
IAS 19.
Explain why your change is not a change in accounting policy that
should be
reflected retrospectively under IAS 8.19(b).
Explain why your change is not the correction of an error that
should be reflected
retrospectively under IAS 8.42(b).
2. In the first full paragraph on page 18 you discuss a $34 million
additional accrual related
to the grandfathering of a small number of cases following the
termination of a profit-
sharing arrangement in your asset recovery business. Please tell us
why it is appropriate
to record this accrual in 2021 given that it appears to relate to
compensation arrangements
dating back to 2015 and reference for us the authoritative literature
you rely upon to
support your accounting. In your response, address the following:
Describe for us the profit-sharing arrangement that was terminated
and explain why it
was terminated.
Tell us what cases or types of cases were grandfathered.
Tell us how your prior accounting complied with the guidance in
IAS 19.
Tell us your consideration of the guidance in IAS 19.24.
Tell us how your current accounting complies with the guidance in
IAS 19.
Explain why your change is not a change in accounting policy that
should be
reflected retrospectively under IAS 8.19(b).
Explain why your change is not the correction of an error that
should be reflected
retrospectively under IAS 8.42(b).
You may contact Mark Brunhofer at 1-202-551-3638 or Sharon Blume at
1-202-551-
3474 with any questions.
FirstName LastNameKenneth A. Brause Sincerely,
Comapany NameBurford Capital Limited
Division of
Corporation Finance
October 4, 2021 Page 2 Office of
Finance
FirstName LastName