SEC Comment Letter for AMERICAN INTERNATIONAL GROUP, (AIG) — Oct 20, 2010
AMERICAN INTERNATIONAL GROUP, INC.
Date: Oct. 20, 2010 · CIK: 0000005272 · Accession: 0000000000-10-061852
AI Filing Summary & Sentiment
File numbers found in text: 001-8787
Letter
Re: American International Group, Inc. Form 8-K Filed on October 18, 2010 File No. 001-8787 Dear Mr. Benmosche: We have reviewed your filing and have the following comment. Please respond to this letter by providing the requested analys is by close of business on October 22, 2010. After reviewing the information you provide in response to this comment, we may have additional comments. 1. We note that the Form 8-K incorporates by re ference a press release discussing the initial public offering of shares of AIA Group Limited and the Hong Kong prospectus posted on October 18, 2010. The press release identifies the Joint Global Coordinators and Joint Sponsors of the Global Offering as well as the Joint Bookrunners and Joint Lead Managers of the Global Offering. Please provide us with a detailed analysis discussing the potential applicabilit y of Section 5 of the Securities Act of 1933 regarding the filing of this Form 8-K. If you believe that your di sclosure is in complia nce with Section 5 of the Securities Act of 1933, please include in your analysis the consideration you gave to Rule 135c of the Securities Act of 1933.
October 20, 2010
Mr. Robert H. Benmosche President and Chief Executive Officer American Internati onal Group, Inc. 70 Pine Street New York, New York 10270
We urge all persons who are responsible for th e accuracy and adequacy of the disclosure in the filing to be certain that the filing include s the information the Securities Exchange Act of 1934 and all applicable Exchange Act rules requir e. Since the company and its management are in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy and adequacy of the disclosures they have made. In responding to our comment, please provide a written statement from the company acknowledging that: • the company is responsible for the adequacy and accuracy of the disclo sure in the filing;
Robert H. Benmosche American Interna tional Group, Inc. October 20, 2010 Page 2
• staff comments or changes to disclosure in response to staff comments do not foreclose the Commission from taking any action with respect to the filing; and
• the company may not assert staff comments as a defense in any proceeding initiated by the Commission or any person under the federa l securities laws of the United States.
Please contact Sebastian Gomez Abero at (202) 551-3578 or me at (202) 551-3715 with any questions. Sincerely, Jeffrey Riedler Assistant Director
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October 20, 2010
Mr. Robert H. Benmosche President and Chief Executive Officer American Internati onal Group, Inc.
70 Pine Street
New York, New York 10270
Re: American International Group, Inc.
Form 8-K Filed on October 18, 2010 File No. 001-8787
Dear Mr. Benmosche:
We have reviewed your filing and have the following comment. Please respond to this
letter by providing the requested analys is by close of business on October 22, 2010.
After reviewing the information you provide in response to this comment, we may have
additional comments.
1. We note that the Form 8-K incorporates by re ference a press release discussing the initial
public offering of shares of AIA Group Limited and the Hong Kong prospectus posted on
October 18, 2010. The press release identifies the Joint Global Coordinators and Joint
Sponsors of the Global Offering as well as the Joint Bookrunners and Joint Lead
Managers of the Global Offering. Please provide us with a detailed analysis discussing
the potential applicabilit y of Section 5 of the Securities Act of 1933 regarding the filing
of this Form 8-K. If you believe that your di sclosure is in complia nce with Section 5 of
the Securities Act of 1933, please include in your analysis the consideration you gave to
Rule 135c of the Securities Act of 1933.
We urge all persons who are responsible for th e accuracy and adequacy of the disclosure
in the filing to be certain that the filing include s the information the Securities Exchange Act of
1934 and all applicable Exchange Act rules requir e. Since the company and its management are
in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy
and adequacy of the disclosures they have made.
In responding to our comment, please provide a written statement from the company
acknowledging that:
• the company is responsible for the adequacy and accuracy of the disclo sure in the filing;
Robert H. Benmosche American Interna tional Group, Inc.
October 20, 2010 Page 2
• staff comments or changes to disclosure in response to staff comments do not foreclose
the Commission from taking any action with respect to the filing; and
• the company may not assert staff comments as a defense in any proceeding initiated by the Commission or any person under the federa l securities laws of the United States.
Please contact Sebastian Gomez Abero at (202) 551-3578 or me at (202) 551-3715 with
any questions.
Sincerely,
Jeffrey Riedler
Assistant Director