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SEC Comment Letter for AMERICAN INTERNATIONAL GROUP, (AIG) — Apr 29, 2014

AMERICAN INTERNATIONAL GROUP, INC.
Date: April 29, 2014 · CIK: 0000005272 · Accession: 0000000000-14-021587

AI Filing Summary & Sentiment

File numbers found in text: 001-08787

Date
April 29, 2014
Author
/s/ Jim B. Rosenberg
Form
UPLOAD
Company
AMERICAN INTERNATIONAL GROUP, INC.

Letter

April 29, 201 4 Via E -mail Mr. Robert H. Benmosche President and Chief Executive Officer American International Group, Inc. 175 Water Street New York, New York 10038

Re: American International Group, Inc. Form 10 -K for the Fiscal Year Ended December 31 , 2013 Filed February 20, 201 4 File No. 001-08787

Dear M r. Benmosche :

We have reviewed your filing and have the following comment . In our comment, we ask you to provide us with information so we may better understand your disclosure s.

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 circumstances, 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 provid ed, we may raise additional comments and/or request that you amend your filing .

Management ’s Discussion and Analysis of Financial Condition and Results of Operations Impairments , page 156

1. You state that additional impairments are expected to occur in t he future due to the fact that continued payment of premiums required to maintain policies will cause the expected lifetime undiscounted cash flows for some policies to become negative in future reporting periods , even in the absence of future changes to the mortality assumptions. Please help us understand how the continued payments of premiums will cause future impairments, which are not currently reflected in your financial statements, when it appears that your impairment test incorporates the payment of future premiums. Further , tell us your estimate of these additional impairments and their timing, and why you have not disclosed this information .

Robert H. Benmosche American International Group, Inc. April 29, 201 4 Page 2

We urge all persons who are responsible for the 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 require. 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 t hey 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 disclosure in the filing;  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 initia ted by the Commission or any person under the federal securitie s laws of the United States.

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

Show Raw Text
April 29, 201 4

Via E -mail
Mr. Robert H. Benmosche
President and Chief Executive Officer
American International Group, Inc.
175 Water Street
New York, New York 10038

Re: American International Group, Inc.
   Form 10 -K for the Fiscal Year Ended December 31 , 2013
   Filed February  20, 201 4
File No. 001-08787

Dear M r. Benmosche :

We have reviewed your filing and have the following comment .  In our comment, we ask
you to provide us with information so we may better understand your disclosure s.

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 circumstances, 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 provid ed, we may raise additional comments  and/or
request that you amend your filing .

Management ’s Discussion and Analysis of Financial Condition and Results of Operations
Impairments , page 156

1. You state that additional impairments are expected to occur in t he future due to the fact
that continued payment of premiums required to maintain policies will cause the expected
lifetime undiscounted cash flows for some policies to become negative in future reporting
periods , even in the absence of future changes to the mortality assumptions.   Please help
us understand how the continued payments of premiums will cause future impairments,
which are not currently reflected in your financial statements, when it appears that your
impairment test incorporates the payment of future premiums.  Further , tell us your
estimate of these additional impairments  and their timing,  and why you have not
disclosed this information .

Robert H. Benmosche
American International Group, Inc.
April 29, 201 4
Page 2

We urge all persons who are responsible for the 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 require.   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 t hey 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 disclosure in the filing;
 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 initia ted by
the Commission or any person under the federal securitie s laws of the United States.

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