260 Interstate North Circle SE
Atlanta, GA 30339-2210
T 770.763.1000
F 770.859.4403

 

11222 Quail Roost Drive
Miami, FL 33157-6596
T 305.253.2244
F 305.252.6987

www.assurant.com


October 8, 2007

Mr. Christopher Menkin
kitmenkin@leasingnews.org
Editor/Publisher, Leasing News
C/O American Leasing LP
14127 Capri Drive, Suite 7
Los Gatos, CA 95032

Dear Mr. Menkin:

On Sept. 21, 2007, Leasing News publis hed, under your byline, an article that purported to review recent news from Assurant related to an investigation by the Securities and Exchange Commission into certain loss mitigation products. The article included direct quotes from Assurant news releases and various company SEC filings as well as other information that has been available to the public for some time. However, it also contained several errors and misstatements of fact and, we believe, unfairly associated several clients to a matter to which they have absolutely no connection.

In an apparent obligatory attempt to obtain comment from Assurant for this article, you called Assurant’s investor relations department and its corporate media relations manager on Sept. 20, 2007. The corporate media relations manager returned your call within three hours that same day and left a message with his telephone number and e-mail contact information. You have not replied to that message or to a second voice message left on Tuesday, Sept. 25.

We ask that you immediately acknowledge through publication of this letter the following errors and
inflammatory inferences:

1. The SEC has not issued a complaint against Assurant or against any of the five employees who were issued “Wells Notices” in late June and early July. None of the employees who have received Wells notices have been charged with any wrongdoing. The issuance of a Wells notice is part of the SEC staff’s standard investigatory process, and the employees who received the notices now have the opportunity to respond to the staff of the SEC before the staff makes its formal recommendation to the Commission.

2. The SEC investigation is not, to our knowledge, connected in any way to Assurant Specialty Property’s Leased and Financed Equipment business. We believe that any statement or inference to the contrary without supporting evidence is wrong and, in fact, unfair. The headline on the story (Leasing Insurance alleged Kickback Scandal) appears to be based on an unattributed statement in the article that “reportedly” describes the content of a complaint that, as noted above, the SEC has not filed. As your article notes later, quoting from a company filing, we believe that the SEC investigation concerns Assurant’s catastrophic reinsurance program. The Leased and Finance Equipment business in not covered by that program.

3. The SEC investigation does not involve any Assurant clients. As our SEC filings state, we believe this matter involves our accounting treatment of a single reinsurance contact that expired in December 2004 and was not renewed. It is neither fair nor accurate to mention clients in any context with this investigation. We believe that doing so suggests an attempt to bias the market against these companies because of their association with Assurant.

4. The SEC investigation does not involve lobbying activities. The mention in this article of
information that we publicly disclose regarding the activities of Assurant’s government relations staff
is out of context and infers illegality where there is none.

Your Web site states that the mission of your publication is to serve a source of “independent, unbiased and fair news about the leasing industry.” Your “policy statement” emphasizes “Fairness always.” We believe that this article failed in many respects to meet the standards that you have set for yourself. We hope that in the interest of fairness, you will print this letter prominently on your Web site and also distribute it to your registered subscribers.

Sincerely yours,

James A. Sykes
Director, External Communications
Assurant Solutions/Assurant Specialty Property
770.763.1015
james.sykes@assurant.com