United States securities and exchange commission logo
December 8, 2021
Neil Greenspan
Chief Financial Officer
Greenlight Capital Re, Ltd.
65 Market Street, Suite 1207, Jasmine Court, P.O. Box 31110
Camana Bay, Grand Cayman, Cayman Islands
KY1-1205
Re: Greenlight Capital
Re, Ltd.
Form 10-K filed
March 10, 2021
Response dated
November 12, 2021
File No. 001-33493
Dear Mr. Greenspan:
We have reviewed your November 12, 2021 response to our comment
letter and have the
following comment. In our comment, we may ask you to provide us with
information so we may
better understand your disclosure.
Please respond to this comment within ten business days by
providing the requested
information or advise us as soon as possible when you will respond. If
you do not believe our
comment applies to your facts and circumstances, please tell us why in
your response.
After reviewing your response to this comment, we may have
additional
comments. Unless we note otherwise, our references to prior comments are
to comments in our
October 18, 2021 letter.
Form 10-K filed March 10, 2021
Liquidity and Capital Resources, page 73
1. Please refer to comment
1. Please revise future filings to discuss the impact of contracts
cancelled separately
from other types of adjustments (e.g. novation, commutation, etc.) on
historical revenue and
other relevant metrics for the periods presented, and discuss
appropriate facts and
circumstances to fully describe any material cancellation or
adjustment.
You may contact Mike Volley, Staff Accountant at 202-551-3437 or
Amit Pande, Branch
Chief, at 202-551-3423 if you have questions regarding comments on the
financial statements
and related matters.
Neil Greenspan
Greenlight Capital Re, Ltd.
December 8, 2021
Page 2
FirstName LastNameNeil Greenspan Sincerely,
Comapany NameGreenlight Capital Re, Ltd.
Division of Corporation Finance
December 8, 2021 Page 2 Office of Finance
FirstName LastName