SEC Comment Letter 0000000000-24-009360 to LOEWS CORP (L) (CIK 0000060086) (L)
LOEWS CORP (L) (CIK 0000060086)
Date: Aug. 15, 2024 · CIK: 0000060086 · Accession: 0000000000-24-009360
AI Filing Summary & Sentiment
File numbers found in text: 001-06541
Letter
August 15, 2024 Jane Wang Senior Vice President and Chief Financial Officer Loews Corporation 9 West 57th Street New York, NY 10019-2714 Re:Loews Corporation Form 10-K for Fiscal Year Ended December 31, 2023 File No. 001-06541 Dear Jane Wang: We have limited our review of your filing to the financial statements and related disclosures and have the following comments. 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 Property and Casualty Operations, page 47 1.We note your disclosure of “underlying loss ratio” and “underlying combined ratio” on page 47, which are presented as “loss ratio excluding catastrophes and development” and “combined ratio excluding catastrophes and development,” respectively, in the table on page 48. 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. Altium Packaging, page 104 We note your disclosure on page 5 that you own 53% of Altium Packaging in addition to your disclosure on page 104 that you deconsolidated this subsidiary in 2021 when you sold approximately 47% of Altium Packaging to GIC. Please explain in further detail the 2.
August 15, 2024 Page 2 “certain participating rights with GIC related to capital allocation and other decisions” and any other terms of the sale to GIC that resulted in your accounting for your investment in Altrium Packaging under the equity method of accounting, effective April 1, 2021. 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 any questions. Sincerely, Division of Corporation Finance Office of Finance
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August 15, 2024
Jane Wang
Senior Vice President and Chief Financial Officer
Loews Corporation
9 West 57th Street
New York, NY 10019-2714
Re:Loews Corporation
Form 10-K for Fiscal Year Ended December 31, 2023
File No. 001-06541
Dear Jane Wang:
We have limited our review of your filing to the financial statements and related
disclosures and have the following comments.
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
Property and Casualty Operations, page 47
1.We note your disclosure of “underlying loss ratio” and “underlying combined ratio” on
page 47, which are presented as “loss ratio excluding catastrophes and development” and
“combined ratio excluding catastrophes and development,” respectively, in the table on
page 48. 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.
Altium Packaging, page 104
We note your disclosure on page 5 that you own 53% of Altium Packaging in addition to
your disclosure on page 104 that you deconsolidated this subsidiary in 2021 when you
sold approximately 47% of Altium Packaging to GIC. Please explain in further detail the 2.
August 15, 2024
Page 2
“certain participating rights with GIC related to capital allocation and other decisions” and
any other terms of the sale to GIC that resulted in your accounting for your investment in
Altrium Packaging under the equity method of accounting, effective April 1, 2021.
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
any questions.
Sincerely,
Division of Corporation Finance
Office of Finance