SEC Comment Letter 0000000000-24-009361 to CNA FINANCIAL CORP (CNA) (CIK 0000021175) (CNA)
CNA FINANCIAL CORP (CNA) (CIK 0000021175)
Date: Aug. 15, 2024 · CIK: 0000021175 · Accession: 0000000000-24-009361
AI Filing Summary & Sentiment
File numbers found in text: 001-05823
Letter
August 15, 2024 Scott Lindquist Executive Vice President and Chief Financial Officer CNA Financial Corporation 151 N. Franklin Chicago, IL 60606 Re:CNA Financial Corporation Form 10-K for Fiscal Year Ended December 31, 2023 File No. 001-05823 Dear Scott Lindquist: We have limited our review of your filing to the financial statements and related disclosures and have the following comment. Please respond to this letter 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 a comment applies to your facts and circumstances, please tell us why in your response. After reviewing your response to this letter, we may have additional comments. Form 10-K for Fiscal Year Ended December 31, 2023 Segment Results, page 33 1.We note your disclosure of “underlying loss ratio” and “underlying combined ratio” on page 33, which are presented as “loss ratio excluding catastrophes and development” and “combined ratio excluding catastrophes and development,” respectively, in the tables on pages 36, 38, and 40. Please tell us how you determined that these ratios do not constitute non-GAAP financial measures considering these measures exclude the impact of catastrophe losses and development-related items. Refer to Rule 101(a) of Regulation G and Question 100.05 of the Division of Corporation Finance's C&DI on Non-GAAP Financial Measures. Please revise future filings as applicable, also ensuring consistent use of terminology. In closing, we remind you that the company and its management are responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the staff. Please contact William Schroeder at 202-551-3294 or John Spitz at 202-551-3484 with
August 15, 2024 Page 2 any questions. Sincerely, Division of Corporation Finance Office of Finance
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August 15, 2024
Scott Lindquist
Executive Vice President and Chief Financial Officer
CNA Financial Corporation
151 N. Franklin
Chicago, IL 60606
Re:CNA Financial Corporation
Form 10-K for Fiscal Year Ended December 31, 2023
File No. 001-05823
Dear Scott Lindquist:
We have limited our review of your filing to the financial statements and related
disclosures and have the following comment.
Please respond to this letter 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 a
comment applies to your facts and circumstances, please tell us why in your response.
After reviewing your response to this letter, we may have additional comments.
Form 10-K for Fiscal Year Ended December 31, 2023
Segment Results, page 33
1.We note your disclosure of “underlying loss ratio” and “underlying combined ratio” on
page 33, which are presented as “loss ratio excluding catastrophes and development” and
“combined ratio excluding catastrophes and development,” respectively, in the tables on
pages 36, 38, and 40. Please tell us how you determined that these ratios do not constitute
non-GAAP financial measures considering these measures exclude the impact of
catastrophe losses and development-related items. Refer to Rule 101(a) of Regulation G
and Question 100.05 of the Division of Corporation Finance's C&DI on Non-GAAP
Financial Measures. Please revise future filings as applicable, also ensuring consistent use
of terminology.
In closing, we remind you that the company and its management are responsible for the
accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or
absence of action by the staff.
Please contact William Schroeder at 202-551-3294 or John Spitz at 202-551-3484 with
August 15, 2024
Page 2
any questions.
Sincerely,
Division of Corporation Finance
Office of Finance