SEC Comment Letter for AMERICAN INTERNATIONAL GROUP, (AIG) — May 8, 2013
AMERICAN INTERNATIONAL GROUP, INC.
Date: May 8, 2013 · CIK: 0000005272 · Accession: 0000000000-13-025430
AI Filing Summary & Sentiment
File numbers found in text: 001-08787
Letter
May 8, 201 3 Via E -mail Mr. Robert H. Benmosche President and Chief Executive Officer American International Group, Inc. 180 Maiden Lane New York, New York 10038
Re: American International Group, Inc. Form 10 -K for the Fiscal Year Ended December 31 , 2012 Filed February 21, 201 3 File No. 001-08787
Dear M r. Benmosche :
We have reviewed your April 11 , 201 3 response to our March 28 , 201 3 letter and have the following comment.
Please respond to this letter within 10 business days by providing us the requested information or by advising us when you will provide the requested response. If you do not believe the comment appl ies to your facts and circums tances, please tell us why in your response. Please furnish us a letter on EDGAR under the form type label CORRESP that key s your response to our comment .
After reviewing the information provide d, we may raise additional comments and/or request that you amend your filing .
Notes to Consolidated Financial Statements
20. Statutory Financial Data and Restrictions, page 314
1. Please refer to your response to comment three. Your revised disclosure in the first paragraph on page seve n only includes the aggregate minimum required statutory capital and surplus for your “domestic” Property Casualty insurance subsidiaries. Please provide us revised proposed disclosure that also includes the minimum required statutory capital and surplus for your foreign Property Casualty insurance subsidiaries. In addition you also state that all U.S. insurance subsidiaries individually exceeded the minimum required statutory capital and surplus. Please provide us revised proposed disclosure that states whether all foreign insurance subsidiaries individually exceeded the minimum required statutory capital and surplus. If certain foreign subsidiaries have not met the minimum requirements, please disclose the expected effects that this deficiency will hav e on your future financial position and results of operations , if material.
Robert H. Benmosche American International Group, Inc. May 8, 201 3 Page 2
You may c ontact Vanessa Robertson, Staff Accountant, at (202) 551 -3649 or Joel Parker , Accounting Branch Chief, at (202) 551 -3651 if you have questions regarding the comment . In this regard, do not hesitate to contact me at (202) 551 -3679 .
Sincerely,
/s/ Jim B. Rosenberg
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May 8, 201 3 Via E -mail Mr. Robert H. Benmosche President and Chief Executive Officer American International Group, Inc. 180 Maiden Lane New York, New York 10038 Re: American International Group, Inc. Form 10 -K for the Fiscal Year Ended December 31 , 2012 Filed February 21, 201 3 File No. 001-08787 Dear M r. Benmosche : We have reviewed your April 11 , 201 3 response to our March 28 , 201 3 letter and have the following comment. Please respond to this letter within 10 business days by providing us the requested information or by advising us when you will provide the requested response. If you do not believe the comment appl ies to your facts and circums tances, please tell us why in your response. Please furnish us a letter on EDGAR under the form type label CORRESP that key s your response to our comment . After reviewing the information provide d, we may raise additional comments and/or request that you amend your filing . Notes to Consolidated Financial Statements 20. Statutory Financial Data and Restrictions, page 314 1. Please refer to your response to comment three. Your revised disclosure in the first paragraph on page seve n only includes the aggregate minimum required statutory capital and surplus for your “domestic” Property Casualty insurance subsidiaries. Please provide us revised proposed disclosure that also includes the minimum required statutory capital and surplus for your foreign Property Casualty insurance subsidiaries. In addition you also state that all U.S. insurance subsidiaries individually exceeded the minimum required statutory capital and surplus. Please provide us revised proposed disclosure that states whether all foreign insurance subsidiaries individually exceeded the minimum required statutory capital and surplus. If certain foreign subsidiaries have not met the minimum requirements, please disclose the expected effects that this deficiency will hav e on your future financial position and results of operations , if material. Robert H. Benmosche American International Group, Inc. May 8, 201 3 Page 2 You may c ontact Vanessa Robertson, Staff Accountant, at (202) 551 -3649 or Joel Parker , Accounting Branch Chief, at (202) 551 -3651 if you have questions regarding the comment . In this regard, do not hesitate to contact me at (202) 551 -3679 . Sincerely, /s/ Jim B. Rosenberg Jim B. Rosenberg Senior Assistant Chief Accountant