SEC Comment Letter for AMERICAN INTERNATIONAL GROUP, (AIG) — Jun 15, 2018
AMERICAN INTERNATIONAL GROUP, INC.
Date: June 15, 2018 · CIK: 0000005272 · Accession: 0000000000-18-018561
AI Filing Summary & Sentiment
File numbers found in text: 001-08787
Letter
June 15, 2018 Siddhartha Sankaran Executive Vice President and Chief Financial Officer AMERICAN INTERNATIONAL GROUP INC 175 Water Street New York, New York 10038 Re:AMERICAN INTERNATIONAL GROUP INC Form 10-K for the Year Ended December 31, 2017 Filed February 16, 2018 File No. 001-08787 Dear Mr. Sankaran: We have reviewed your April 10, 2018 response to our comment letter and have the following comment. In our comment, we ask you to provide us with information so we may better understand your disclosure. Please respond to the comment within ten business days by providing the requested information or advise us as soon as possible when you will respond. If you do not believe our comment applies to your facts and circumstances, please tell us why in your response. After reviewing your response to the comment, we may have additional comments. Unless we note otherwise, our references to prior comments are to comments in our March 28,2018 letter. Form 10-K for the Year Ended December 31, 2017 Notes to Consolidated Financial Statements 13. Insurance Liabilities Liability for Unpaid Losses and Loss Adjustment Expenses (Loss Reserves) Loss Development Information Supplemental Information , page 237 1.Please refer to your response to our prior comment 2. We continue to believe that ASC 944-40-50-4B requires disclosure in a tabular format, as of the date of your latest annual balance sheet presented, undiscounted information about claims development by accident year on a net basis after risk mitigation through reinsurance. That is, the effects of risk
FirstName LastNameSiddhartha Sankaran Comapany NameAMERICAN INTERNATIONAL GROUP INC June 15, 2018 Page 2 FirstName LastName Siddhartha Sankaran AMERICAN INTERNATIONAL GROUP INC June 15, 2018 Page 2 mitigation are depicted by accident year for each calendar year of the table, not simply the most recent calendar year. While we appreciate that there are unique aspects to your Adverse Development Reinsurance Agreement and understand that your depiction of claims development on a gross basis provides useful information, we note that your current disclosure does not appear to comply with this requirement. Please propose incremental tabular disclosure that depicts as of your latest annual balance sheet date undiscounted information about your reinsurance recoverable by accident year for the number of years depicted in your existing tables. Also propose disclosure to describe the method used to allocate your reinsurance recoverable under the Adverse Development Reinsurance Agreement to the six lines of business to which it relates and to explain the factors that may cause these allocations to change, as disclosure within the “Reinsurance” factor on page 237 is vague. You may contact Frank Wyman at 202-551-3660 or Jim Rosenberg at 202-551-3679 if you have questions. Division of Corporation Finance Office of Healthcare & Insurance
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June 15, 2018
Siddhartha Sankaran
Executive Vice President and Chief Financial Officer
AMERICAN INTERNATIONAL GROUP INC
175 Water Street
New York, New York 10038
Re:AMERICAN INTERNATIONAL GROUP INC
Form 10-K for the Year Ended December 31, 2017
Filed February 16, 2018
File No. 001-08787
Dear Mr. Sankaran:
We have reviewed your April 10, 2018 response to our comment letter and have the
following comment. In our comment, we ask you to provide us with information so we may
better understand your disclosure.
Please respond to the comment within ten business days by providing the requested
information or advise us as soon as possible when you will respond. If you do not believe our
comment applies to your facts and circumstances, please tell us why in your response.
After reviewing your response to the comment, we may have additional
comments. Unless we note otherwise, our references to prior comments are to comments in our
March 28,2018 letter.
Form 10-K for the Year Ended December 31, 2017
Notes to Consolidated Financial Statements
13. Insurance Liabilities
Liability for Unpaid Losses and Loss Adjustment Expenses (Loss Reserves)
Loss Development Information
Supplemental Information , page 237
1.Please refer to your response to our prior comment 2. We continue to believe that ASC
944-40-50-4B requires disclosure in a tabular format, as of the date of your latest annual
balance sheet presented, undiscounted information about claims development by accident
year on a net basis after risk mitigation through reinsurance. That is, the effects of risk
FirstName LastNameSiddhartha Sankaran
Comapany NameAMERICAN INTERNATIONAL GROUP INC
June 15, 2018 Page 2
FirstName LastName
Siddhartha Sankaran
AMERICAN INTERNATIONAL GROUP INC
June 15, 2018
Page 2
mitigation are depicted by accident year for each calendar year of the table, not simply the
most recent calendar year. While we appreciate that there are unique aspects to your
Adverse Development Reinsurance Agreement and understand that your depiction of
claims development on a gross basis provides useful information, we note that your
current disclosure does not appear to comply with this requirement. Please propose
incremental tabular disclosure that depicts as of your latest annual balance sheet date
undiscounted information about your reinsurance recoverable by accident year for the
number of years depicted in your existing tables. Also propose disclosure to describe the
method used to allocate your reinsurance recoverable under the Adverse Development
Reinsurance Agreement to the six lines of business to which it relates and to explain the
factors that may cause these allocations to change, as disclosure within the “Reinsurance”
factor on page 237 is vague.
You may contact Frank Wyman at 202-551-3660 or Jim Rosenberg at 202-551-3679 if
you have questions.
Division of Corporation Finance
Office of Healthcare & Insurance