September 24, 2024
Bruce Lucas
Chief Executive Officer
Slide Insurance Holdings, Inc.
4221 W. Boy Scout Blvd.
Tampa, FL 33607
Re: Slide Insurance Holdings, Inc.
Amendment No. 2 to Draft Registration Statement on Form S-1
Submitted September 4, 2024
CIK No. 0001886428
Dear Bruce Lucas:
We have reviewed your amended draft registration statement and have the
following
comment.
Please respond to this letter by providing the requested information
and either submitting
an amended draft registration statement or publicly filing your registration
statement on EDGAR.
If you do not believe a comment applies to your facts and circumstances or do
not believe an
amendment is appropriate, please tell us why in your response.
After reviewing the information you provide in response to this letter
and your amended
draft registration statement or filed registration statement, we may have
additional
comments. Unless we note otherwise, any references to prior comments are to
comments in our
August 22, 2024, letter.
General
1. We note your response to prior comment 2 that you are under contract
to acquire
Pawtucket Insurance Company from a subsidiary of Heritage Insurance
Holdings, Inc. We
also note a PR Newswire article, Heritage Announces Strategic
InsurTech Partnership
with Slide, dated November 26, 2021, which discusses what appears to
be a similar
transaction, including a 6% ownership as well as transfers of Pawtucket
and various
licenses and software. With a view towards clarifying disclosure in the
registration
statement regarding the intended transaction and the company's plans to
grow
geographically in the Atlantic coastal specialty markets, please explain
to us the terms of
the contract, as referenced.
September 24, 2024
Page 2
Please contact Katharine Garrett at 202-551-2332 or Lory Empie at
202-551-3714 if you
have questions regarding comments on the financial statements and related
matters. Please
contact Aisha Adegbuyi at 202-551-8754 or James Lopez at 202-551-3536 with any
other
questions.
Sincerely,
Division of
Corporation Finance
Office of Finance
cc: Richard D. Truesdell, Jr., Esq.