SEC Comment Letter for AMERICAN INTERNATIONAL GROUP, (AIG) — Apr 26, 2010
AMERICAN INTERNATIONAL GROUP, INC.
Date: April 26, 2010 · CIK: 0000005272 · Accession: 0000000000-10-022685
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Via Facsimile and U.S. Mail Mail Stop 4720 April 26, 2010 Mr. David L. Herzog Executive Vice President and Chief Financial Officer American Internati onal Group, Inc.
70 Pine Street New York, New York 10270 Dear Mr. Herzog:
We have reviewed your April 13, 20 10 response to our March 29, 2010 letter
regarding your accountin g for certain of your repurchase agreements, securities lending
transactions, or other transact ions involving the transfer of financial assets with an
obligation to repurchase the tr ansferred assets. Beginning with your Form 10-Q for the
quarter ended March 31, 2010, please:
• Revise your accounting policy disclosu re to discuss the circumstances
where your repurchase agreements, s ecurities lending transactions and
dollar roll transactions may be accounted for as sales; and
• Disclose the amounts of these transacti ons that are accounted for as a sale
in the discussion of Off-Balance Sheet Arrangements, or Contractual
Obligations disclosure or othe r section as appropriate.
Please contact me if you have any questions at (202) 551-3679.
S i n c e r e l y ,
Jim B. Rosenberg Senior Assistant Chief Accountant