SEC Company Response from AMERICAN INTERNATIONAL GROUP, (AIG) — Dec 14, 2017
AMERICAN INTERNATIONAL GROUP, INC.
Date: Dec. 14, 2017 · CIK: 0000005272 · Accession: 0001193125-17-369552
AI Filing Summary & Sentiment
Referenced dates: December 5, 2017
Letter
VIA EDGAR CORRESPONDENCE Office of Healthcare & Insurance Securities and Exchange Commission Division of Corporation Finance Re: American International Group, Inc. Form 10-Q for the Quarterly Period Ended September 30, 2017 Filed November 3, 2017 File No. 1-08787
Dear Ms. Robertson:
We are in receipt of your letter dated December 5, 2017 with respect to American International Group, Inc.’s (“AIG,” “we,” or “our”) Quarterly Report on Form 10-Q for the quarterly period ended September 30, 2017 (“Form 10-Q”). This letter sets forth our response to the Staff’s comment contained in your letter.
We have repeated your comment below to facilitate your review.
* * * * *
Management’s Discussion and Analysis of Financial Condition and Results of Operations
Use of Non-GAAP Measures, page
1. “After-tax operating income attributable to AIG” and “pre-tax operating income” that you identify as non-GAAP measures appear to be titles that are the same as, or confusingly similar to, those used for GAAP financial measures and precluded by Item 10(e)(ii)(E) of Regulation S-K. As such, please confirm to us that you will revise the titles of these measures in future filings to provide an appropriate description for each measure that complies with Item 10(e).
AIG Response
We acknowledge the Staff’s comment and hereby confirm that we will revise “after-tax operating income attributable to AIG” to “adjusted after-tax income attributable to AIG” and “pre-tax operating income” to “adjusted pre-tax income” in future filings, beginning with the 2017 Annual Report on Form 10-K.
* * * * *
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
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CORRESP
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CORRESP
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
December 14, 2017
VIA EDGAR CORRESPONDENCE
Ms. Vanessa Robertson
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-Q for the
Quarterly Period Ended September 30, 2017
Filed
November 3, 2017
File No. 1-08787
Dear Ms. Robertson:
We are in receipt of your letter dated December 5, 2017 with respect to American International Group, Inc.’s (“AIG,”
“we,” or “our”) Quarterly Report on Form 10-Q for the quarterly period ended September 30, 2017 (“Form 10-Q”). This letter sets forth
our response to the Staff’s comment contained in your letter.
We have repeated your comment below to facilitate your review.
* * * * *
Management’s Discussion and Analysis of
Financial Condition and Results of Operations
Use of Non-GAAP Measures, page
73
1. “After-tax operating income
attributable to AIG” and “pre-tax operating income” that you identify as non-GAAP measures appear to be titles that are the same as, or confusingly
similar to, those used for GAAP financial measures and precluded by Item 10(e)(ii)(E) of Regulation S-K. As such, please confirm to us that you will revise the titles of these measures in future filings to
provide an appropriate description for each measure that complies with Item 10(e).
AIG Response
We acknowledge the Staff’s comment and hereby confirm that we will revise “after-tax
operating income attributable to AIG” to “adjusted after-tax income attributable to AIG” and “pre-tax operating income” to “adjusted pre-tax income” in future filings, beginning with the 2017 Annual Report on Form 10-K.
* * * * *
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.
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