0001437749-19-023817.txt : 20200526 0001437749-19-023817.hdr.sgml : 20200526 20191203175147 ACCESSION NUMBER: 0001437749-19-023817 CONFORMED SUBMISSION TYPE: CORRESP PUBLIC DOCUMENT COUNT: 1 FILED AS OF DATE: 20191203 FILER: COMPANY DATA: COMPANY CONFORMED NAME: First Trinity Financial CORP CENTRAL INDEX KEY: 0001395585 STANDARD INDUSTRIAL CLASSIFICATION: LIFE INSURANCE [6311] IRS NUMBER: 341991436 STATE OF INCORPORATION: OK FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 7633 EAST 63RD PLACE, SUITE 230 CITY: TULSA STATE: OK ZIP: 74133 BUSINESS PHONE: 918-249-2438 MAIL ADDRESS: STREET 1: 7633 EAST 63RD PLACE, SUITE 230 CITY: TULSA STATE: OK ZIP: 74133 CORRESP 1 filename1.htm ftfc20191202b_corresp.htm

Jones & Keller, P.C.

1999 Broadway, Suite 3150

Denver, Colorado 80202

Telephone: (303) 573-1600

 

December 3, 2019

 

 

VIA EDGAR AND OVERNIGHT COURIER

 

Securities and Exchange Commission

Division of Corporate Finance

100 F Street, N.E.

Washington, D.C. 20549

 

Attention:

David Gessert, Esq.

Division of Corporate Finance

 

Re:

First Trinity Financial Corporation

Registration Statement on Form S-4

Filed October 25, 2019

File No. 333-234331

 

Ladies and Gentlemen:

 

We are submitting this letter on behalf of First Trinity Financial Corporation (the “Company”) in response to oral comments from the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”) relating to the Company’s Registration Statement on Form S-4 (Registration No. 333-234331) filed with the Commission on October 25, 2019 (the “Registration Statement”). Pre-Effective Amendment No. 2 to the Registration Statement (“Amendment No. 2”) was filed today for the purpose of updating the consents of the two independent public accounting firms whose reports are included in the Registration Statement.

 

In addition, the Company hereby acknowledges that:

 

•      should the Commission or the Staff, acting pursuant to delegated authority, declare the filing effective, it does not foreclose the Commission from taking any action with respect to the filing;

 

•      the action of the Commission or the Staff, acting pursuant to delegated authority, in declaring the filing effective, does not relieve the Company from its full responsibility for the adequacy and accuracy of the disclosure in the filing; and

 

•      the Company may not assert Staff comments and the declaration of effectiveness as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.

 

We hope the foregoing answers adequately address the Staff’s comments. Please do not hesitate to contact Reid A. Godbolt by telephone at (303) 573-1600 or by email at rgodbolt@joneskeller.com, with any questions or comments regarding this correspondence.

 

Very truly yours,

 

JONES & KELLER, P.C.

 

/s/ Reid A. Godbolt

Reid A. Godbolt

 

cc via email:

Gregg E. Zahn

Jeffrey J. Wood