United States securities and exchange commission logo
November 29, 2023
Eric J. Martin
Chief Financial Officer
United Fire Group, Inc.
118 Second Avenue SE
Cedar Rapids, IA 52401
Re: United Fire Group,
Inc.
Amendment No. 1 to
Form 10-K for Fiscal Year Ended December 31, 2022
Form 8-K filed
November 1, 2023
File No. 001-34257
Dear Eric J. Martin:
We have limited our review of your filing to the financial
statements and related
disclosures and have the following comments.
Please respond to this letter 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 a
comment applies to your facts and circumstances, please tell us why in
your response.
After reviewing your
response to this letter, we may have additional comments.
Amendment No. 1 to Form 10-K for Fiscal Year Ended December 31, 2022
Item 7. Management's Discussion and Analysis of Financial Condition and
Results of Operations
Financial Highlights, page 32
1. We note your disclosure
of the net underlying loss ratio, which is the net loss ratio less
the impacts of
catastrophes and non-catastrophe prior year reserve development. Please
tell us how you
determined that the net underlying loss ratio does not constitute a non-
GAAP financial measure.
Refer to Rule 101(a) of Regulation G and Question 100.05 of
the Division of
Corporation Finance's Compliance & Disclosure Interpretations ("C&DI")
on Non-GAAP Financial
Measures. Please revise future filings as applicable.
Eric J. Martin
FirstName
United FireLastNameEric
Group, Inc. J. Martin
Comapany 29,
November NameUnited
2023 Fire Group, Inc.
November
Page 2 29, 2023 Page 2
FirstName LastName
Item 8. Financial Statements and Supplementary Data
Note 2. Summary of Investments, page 76
2. We note your disclosure on page 79 of the summary of net investment
gains (losses) for
the periods presented. Please revise future filings to disclose the
portion of unrealized
gains and losses for each period that relate to equity securities
still held at the reporting
date. Refer to ASC 321-10-50-4.
Form 8-K filed November 1, 2023
Certain Performance Measures, page 7
3. We note your disclosure of net underlying loss ratio and
underlying combined ratio in
Exhibit 99.1. Please tell us how you determined that these ratios do
not constitute non-
GAAP financial measures considering the adjustments made to net loss
ratio and
combined ratio, respectively, to arrive at these ratios. Refer to Rule
101(a) of Regulation
G and Question 100.05 of the Division of Corporation Finance's C&DI on
Non-GAAP
Financial Measures. Please revise future filings as applicable.
In closing, we remind you that the company and its management are
responsible for the
accuracy and adequacy of their disclosures, notwithstanding any review,
comments, action or
absence of action by the staff.
Please contact Katharine Garrett at 202-551-2332 or William Schroeder at
202-551-3294
with any questions.
Sincerely,
Division of
Corporation Finance
Office of
Finance