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        Global Legal,

        Compliance, Regulatory

        Affairs and Government
        Affairs

        80 Pine Street, 13th
        Floor

        New York, NY 10005

        www.aig.com

        James J. Killerlane
        III

        Associate General

        Counsel and Assistant
        Secretary

        T 212 770 8111

        F 866 215 0326

        james.killerlane@aig.com

September 18, 2018

VIA EDGAR CORRESPONDENCE

Mr. Jim Rosenberg

Mr. Frank Wyman

Office of Healthcare & Insurance

Securities and Exchange Commission

Division of Corporation Finance

100 F Street, NE

Mail Stop 4720

Washington, D.C. 20549

 Re: American
International Group, Inc.

Form 10-K for the Year Ended December 31, 2017

Filed February 16, 2018

File No. 001-08787

Dear Messrs. Rosenberg and Wyman,

Thank you for your letter dated August
24, 2018 setting forth additional comments of the staff of the Division of Corporation Finance (the “Staff”) of the
Securities and Exchange Commission (the “Commission”) on our Annual Report on Form 10-K for the fiscal year ended December 31,
2017 (the “Form 10-K”). We have considered the Staff’s comments carefully. This letter sets forth our response
to the Staff’s comments contained in your letter.

We have repeated your comments below to facilitate your review.

*    *    *    *    *

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

We acknowledge the information provided in your response as
well as the additional disclosure discussed in our call on August 7, 2018. Please provide us with proposed disclosure in total
to be included in your next Form 10-K, revised from that included on page 10 in your response, to address the following for the
US Excess Casualty line of business representing an example of the disclosure that you will provide for all six lines of business
subject to the Adverse Development Reinsurance agreement:

• Explain specifically
how the amounts in the "U.S. Excess Casualty Table, Net of ADC Impact" shown on page 10 of your response were derived
from the "US. Excess Casualty (existing Table in our 2017 Form 10-K)" also shown on page 10 and from the table to be
included as a result of the next bullet.

• A table showing attribution
of the reinsurance recoverable under the Adverse Development Reinsurance agreement by accident year beginning with the 2016 calendar
year.

• Include a discussion
as a note to the table referred to in the preceding bullet or a cross reference to a discussion that addresses the method used
to allocate your reinsurance recoverable under the Adverse Development Reinsurance Agreement to each of the accident years within
the six lines of business and to explain the factors that may cause these allocations to change. In this regard, your response
to our previous comment that you addressed on pages 14 and 15 will suffice, if revised to clearly convey that the allocations
are re-estimated at the end of each period and to highlight the factors that cause the allocations to change.

AIG Response

In future filings, beginning with our Annual Report on Form
10-K for the year ended 2018, we will revise our existing disclosures for each of the six lines of business subject to the Adverse
Development Reinsurance Agreement (the “ADC”) using U.S. Casualty as an example as illustrated below:

[We have included excerpts from our existing disclosure for
U.S. Excess Casualty from page 240 of our 2017 Form 10-K. We also highlighted the header for the two new additional tables for
the Staff’s convenience and underlined additional disclosure].

U.S. Excess Casualty

During 2017, we recognized $254 million of unfavorable prior
year development in Excess Casualty driven by higher than expected loss emergence.

During 2016, we recognized $1.1 billion of unfavorable prior
year development in Excess Casualty driven by continued higher than expected loss emergence.

    2

    Incurred
    Losses and Allocated Loss Adjustment Expenses, Undiscounted and Net of Reinsurance

    Years
    Ended December 31, (dollars in millions)

    December
    31, 2017

    Accident
    Year

    2008

    2009

    2010

    2011

    2012

    2013

    2014

    2015

    2016

    2017

    2017
    Prior Year Development Excluding the Impact of Adverse Development Reinsurance Agreement

    Total
    of IBNR Liabilities Plus Expected Development on Reported Losses

    Cumulative
    Number of Reported Claims

    Incurred
    Impact of Adverse Development Reinsurance Agreement

    2017
    (Net of Impact of Adverse Development Reinsurance Agreement)

    Total
    of IBNR Liabilities Net of Impact of Adverse Development Reinsurance Agreement

    Unaudited

    2008
    $
    1,948
    $
    1,968
    $
    2,146
    $
    1,933
    $
    1,819
    $
    1,875
    $
    1,714
    $
    1,662
    $
    1,635

    $
    1,658
    $
    23
    $
    188

    4,662
    $
    (176)
    $
    1,482
    $
    12

    2009

    1,831

    1,897

    1,797

    1,638

    1,457

    1,321

    1,407

    1,518

    1,522

    4

    210

    3,789

    (169)

    1,353

    41

    2010

    1,863

    2,076

    2,076

    1,771

    1,640

    1,723

    1,719

    1,706

    (13)

    359

    3,588

    (260)

    1,446

    99

    2011

    1,766

    1,807

    1,581

    1,416

    1,521

    1,606

    1,623

    17

    350

    3,520

    (256)

    1,367

    94

    2012

    1,588

    1,382

    1,226

    1,477

    1,530

    1,481

    (49)

    371

    3,398

    (323)

    1,158

    48

    2013

    1,073

    973

    1,113

    1,258

    1,178

    (80)

    441

    2,722

    (309)

    869

    132

    2014

    849

    968

    1,157

    1,135

    (22)

    583

    2,088

    (355)

    780

    228

    2015

    892

    1,334

    1,320

    (14)

    602

    1,770

    (425)

    895

    177

    2016

    790

    1,029

    239

    870

    1,061

    -

    1,029

    870

    2017

    758

    725

    376

    -

    758

    725

    Total

    $
    13,410
    $
    105

    $
    (2,273)
    $
    11,137

    Cumulative
    Paid Losses and Allocated Loss Adjustment Expenses, Net of

    Reinsurance
    from the table below

    (7,120)

    -

    -

    (7,120)

    Liabilities
    for losses and loss adjustment expenses and prior year

    development
    before     accident year 2008, net of reinsurance

    1,649

    141

    (864)

    785

    Unallocated
    loss adjustment expense prior year development

    8

    Liabilities
    for losses and loss adjustment expenses and prior year loss

    development,
    net of reinsurance

    $
    7,939
    $
    254

    $
    (3,137)
    $
    4,802

    3

The following table
provides our attribution of our reinsurance recoverable for the ADC only (included in the tables above):

Refer to Note 13 Insurance Liabilities
(page 237) for discussion of our attribution methodology of the ADC to lines of business and accident years for which it relates.

In addition to the above disclosures, we have divided our response
to the Staff’s requests to respond separately to each of the included bullets.

 1. Explain specifically how the amounts in the "U.S.
Excess Casualty Table, Net of ADC Impact" shown on page 10 of your response were derived from the "US. Excess Casualty
(existing Table in our 2017 Form 10-K)" also shown on page 10 and from the table to be included as a result of the next bullet.

    4

AIG Response

The ADC provides reinsurance protection
from NICO of 80 percent of the future aggregate cumulative claims payments for the Covered Lines in excess of $25
billion for claims paid after December 31, 2015 for losses incurred prior to January 1, 2016 with NICO’s limit of liability
under the contract of $20 billion (calculated as 80 percent of the difference between the $50 billion contract limit and the $25
billion contract attachment point). Thus, any 80 percent of the change in incurred loss for covered claims (i.e. “Prior Year
Development” or “PYD”) is ceded to NICO.

In order to recalculate and
derive the "U.S. Excess Casualty Table, Net of ADC Impact" for the 2016 column shown on page 3 above (and on page 10
of our previous response letter), since we retain 20% of the PYD, we multiplied the total PYD (a below)
by our retention of 20% (b below) for each accident year to arrive at the PYD retained by AIG
(c below). We then subtracted the PYD retained by AIG for 2016 from the ending 2017 calendar year
(g below) to recalculate the 2016 amounts (d below). For the 2017
calendar year, we subtracted the column in our existing 10-K disclosure titled “Incurred
Impact of Adverse Development Reinsurance Agreement” from the 2017 column in our existing 10-K disclosure. We
have also provided the table below to show the recalculations:

    Recalculation
    for 2016 column

    Recalculation
    for 2017 column

    As
    included in existing 10-K table

    2016
    column as part of the To be included in future filings on page 3 above

    As
    included in existing 10-K table

    2017
    column as part of the To be included in future filings on page 3 above

    Accident

                                                                                Year

    2017
    Prior Year Development, Excluding the impact of Adverse Development Reinsurance Agreement
    Percentage
    of PYD retained by AIG ( 80% is covered  by ADC) (1) / (2)
    PYD
    retained by AIG
    2016
    (2017 less PYD retained by AIG)

    2017
    Incurred
    Impact of Adverse Development Cover
    2017

    a
    b
    c
    = (a x b)
    d
    = (g-c)

    e
    f
    g=
    e+f

    2008
    23

    20%
                         5

    1,477

    1,658

    (176)
    1,482

    2009
    4

    20%
                         1

    1,352

    1,522

    (169)
    1,353

    2010
    (13)
    20%
                        (3)
    1,448

    1,706

    (260)
    1,446

    2011
    17

    20%
                         3

    1,364

    1,623

    (256)
    1,367

    2012
    (49)
    20%
                      (10)
    1,168

    1,481

    (323)
    1,158

    2013
    (80)
    20%
                      (16)
    885

    1,178

    (309)
    869

    2014
    (22)
    20%
                        (4)
    784

    1,135

    (355)
    780

    2015
    (14)
    20%
                        (3)
    898

    1,320

    (425)
    895

    2016
    239

    N/A
                      239

    790

    1,029

    0

    1,029

    2017
    0

    N/A
    0

    0

    758

    0

    758

    Total

    10,166

    13,410

    (2,273)
    11,137

    Notes:

    (1) Where N/A is noted such
    AY is not covered by the ADC.

    (2) The retention percentage will vary for each
    of the six lines of business since not all blocks of business are covered by the ADC.  For example, the Property  block
    of business within U.S. Property and Special Risks is not covered by the ADC, therefore our retention percentage would be
    higher.

    5

 2. A table showing attribution of the reinsurance recoverable under the Adverse Development Reinsurance agreement by accident
year beginning with the 2016 calendar year.

Please refer to the table provided
on page 4 herein.

 3. Include a discussion as a note to the table referred to in the preceding bullet or a cross reference
to a discussion that addresses the method used to allocate your reinsurance recoverable under the Adverse Development Reinsurance
Agreement to each of the accident years within the six lines of business and to explain the factors that may cause these allocations
to change. In this regard, your response to our previous comment that you addressed on pages 14 and 15 will suffice, if revised
to clearly convey that the allocations are re-estimated at the end of each period and to highlight the factors that cause the allocations
to change.

AIG Response

We will include a note to the table as
a cross reference (as illustrated on page 4 above) to our disclosure on page 237 to address the Staff’s question. In future
filings, we will also replace our disclosure on page 237, with the following disclosure. For the Staff’s convenience, we
have underlined the changes from our previous response letter dated July 9, 2018.

Reinsurance:
Our reinsurance program varies by exposure type and may change from year to year. This may affect the comparability of the data
presented in our tables. We have provided the impact of the Adverse Development Reinsurance Agreement (ADC) in an additional table
below our Incurred Losses and Allocated Loss Adjustment tables. The impact of the ADC is shown beginning in 2016 given the retroactive
date of the contract and coincides with the effective date of the contract. For the lines of business covered by the agreement
(U.S. Workers’ Compensation, U.S. Excess Casualty, U.S. Other Casualty, U.S. Financial Lines, U.S. Property and Special Risks
and U.S. Personal Insurance or collectively, the “Covered Lines”), an attribution of the loss recoveries to
the line of business by calendar year and accident year is performed based on the underlying distribution of the losses subject
to the agreement. Specifically, the future cash claim payments for all subject incurred losses were projected into
future years based on the same actuarial assumptions underlying the related reserves. The reinsurance terms of the ADC were
then used to identify the future claims payments for which 80% will be reimbursed by NICO. At each reporting period, the attribution
of the ADC recoveries is performed. The factors that could cause the attribution to lines of business and accident year to change
include changes in underlying actuarial assumptions as to timing and amount of future claim payments.

	*    *    *    *    *

    6

If you have any questions or require any
additional information, please do not hesitate to contact me at (212) 770-8111.

    Very truly yours,

    /s/ James J. Killerlane III

        Associate General Counsel

        and Assistant Secretary

        American International Group, Inc.

    7