SEC Company Response from AMERICAN INTERNATIONAL GROUP, (AIG) — Dec 22, 2011
AMERICAN INTERNATIONAL GROUP, INC.
Date: Dec. 22, 2011 · CIK: 0000005272 · Accession: 0001193125-11-350176
AI Filing Summary & Sentiment
File numbers found in text: 001-08787
Referenced dates: December 9, 2011
Letter
VIA EDGAR CORRESPONDENCE Securities and Exchange Commission Division of Corporation Finance Re: American International Group, Inc. Form 10-Q for the Quarterly Period Ended September 30, 2011 Filed November 3, 2011 File No. 001-08787
Dear Mr. Rosenberg:
We are in receipt of your letter dated December 9, 2011 with respect to American International Group, Inc.’s (“AIG”) Quarterly Report on Form 10-Q for the quarterly period ended September 30, 2011 (“Form 10-Q”). This letter sets forth AIG’s response to the Staff’s comment contained in your letter.
AIG acknowledges that the adequacy and accuracy of the disclosure in the Form 10-Q is the responsibility of AIG, that Staff comments or changes to disclosure in response to Staff comments do not foreclose the Securities and Exchange Commission (the “Commission”) from taking any action with respect to the Form 10-Q and that Staff comments may not be asserted by AIG as a defense in any proceeding initiated by the Commission or any person under the Federal securities laws of the United States.
We have repeated your comment below to facilitate your review.
* * * * *
Item 2. Management’s Discussion and Analysis of Financial Condition and Results of Operations
SunAmerica
Investments, page 107
1. You state that SunAmerica’s annuity and universal life products have minimum guaranteed interest rates ranging from 1.0 percent to 5.5 percent. Please provide us proposed disclosure to be included in future periodic filings that quantifies the distribution of annuity and universal life account values within this range.
Mr. Jim B. Rosenberg
Securities and Exchange Commission
Page 2
AIG Response
In response to the Staff’s comment, in future filings, AIG will expand the disclosures related to SunAmerica’s fixed annuity and universal life products by presenting the following information to quantify the distribution of fixed annuity and universal life account values and the associated minimum guaranteed interest rates, in a format similar to the presentation below.
The following table presents account values by range of current minimum guaranteed interest rates for SunAmerica’s universal life products and fixed annuities:
(in millions)
September 30, 2011
Minimum Guaranteed
Interest Rate
Total
Universal life
insurance
1%
> 1% - 2%
> 2% - 3%
> 3% - 4%
> 4% - 5%
> 5% - 5.5%
Subtotal
$ 10,329
Fixed annuities
1%
> 1% - 2%
> 2% - 3%
> 3% - 4%
> 4% - 5%
> 5% - 5.5%
Subtotal
$ 92,386
Total
$ 102,715
* * * * *
If you have any questions or require any additional information, please do not hesitate to contact me at (212) 770-5123.
Very truly yours,
/s/ Kathleen E. Shannon
Show Raw Text
CORRESP
1
filename1.htm
Correspondence
(AIG Letterhead)
December 22, 2011
VIA EDGAR CORRESPONDENCE
Mr. Jim B. Rosenberg
Senior
Assistant Chief Accountant
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-Q for the Quarterly Period Ended September 30, 2011
Filed November 3, 2011
File No. 001-08787
Dear Mr. Rosenberg:
We
are in receipt of your letter dated December 9, 2011 with respect to American International Group, Inc.’s (“AIG”) Quarterly Report on Form 10-Q for the quarterly period ended September 30, 2011 (“Form 10-Q”). This
letter sets forth AIG’s response to the Staff’s comment contained in your letter.
AIG acknowledges that the
adequacy and accuracy of the disclosure in the Form 10-Q is the responsibility of AIG, that Staff comments or changes to disclosure in response to Staff comments do not foreclose the Securities and Exchange Commission (the “Commission”)
from taking any action with respect to the Form 10-Q and that Staff comments may not be asserted by AIG as a defense in any proceeding initiated by the Commission or any person under the Federal securities laws of the United States.
We have repeated your comment below to facilitate your review.
* * * * *
Item 2. Management’s Discussion and Analysis of Financial Condition and Results of Operations
SunAmerica
Investments, page 107
1.
You state that SunAmerica’s annuity and universal life products have minimum guaranteed interest rates ranging from 1.0 percent to 5.5 percent. Please provide
us proposed disclosure to be included in future periodic filings that quantifies the distribution of annuity and universal life account values within this range.
Mr. Jim B. Rosenberg
Securities and Exchange Commission
Page 2
AIG Response
In response to the Staff’s comment, in future filings, AIG will expand the disclosures related to SunAmerica’s fixed annuity and universal life products by presenting the following information
to quantify the distribution of fixed annuity and universal life account values and the associated minimum guaranteed interest rates, in a format similar to the presentation below.
The following table presents account values by range of current minimum guaranteed interest rates for SunAmerica’s universal life products and fixed annuities:
(in millions)
September 30, 2011
Minimum Guaranteed
Interest Rate
Total
Universal life
insurance
1%
> 1% - 2%
> 2% - 3%
> 3% - 4%
> 4% - 5%
> 5% - 5.5%
Subtotal
$
10,329
Fixed annuities
1%
> 1% - 2%
> 2% - 3%
> 3% - 4%
> 4% - 5%
> 5% - 5.5%
Subtotal
$
92,386
Total
$
102,715
* * * * *
If you have any questions or require any additional information, please do not hesitate to contact me at
(212) 770-5123.
Very truly yours,
/s/ Kathleen E. Shannon
Kathleen E. Shannon
Senior
Vice President
and Deputy General Counsel