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March 16, 2023
Mark McGivney
Chief Financial Officer
Marsh & McLennan Companies, Inc.
1166 Avenue of the Americas
New York, New York 10036
Re:Marsh & McLennan Companies, Inc.
Form 10-K for Fiscal Year Ended December 31, 2022
File No. 001-05998
Dear Mark McGivney:
            We have limited our review of your filing to the financial statements and related
disclosures and have the following comments.  In some of our comments, we may ask you to
provide us with information so we may better understand your disclosure.
            Please respond to these comments 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 our
comments apply to your facts and circumstances, please tell us why in your response.
            After reviewing your response to these comments, we may have additional comments.
Form 10-K for Fiscal Year Ended December 31, 2022
Consolidated Revenue and Expense, page 43
1.We note the prominence and significance of your references to trends in underlying
revenue throughout your MD&A, in your earnings press release included in Form 8-K
filed on January 26, 2023 and your related earnings conference call.  We further note your
disclosure on page 43 that underlying revenue measures the change in revenue by
isolating certain noted items.  Please revise future periodic filings to disclose the amount
of underlying revenue (in total, by segment, etc.) for each period presented, provide a
reconciliation detailing the calculation of underlying revenue and clearly label the
measures as non-GAAP.  Refer to Item 10(e) of Regulation S-K for guidance and other
disclosure requirements.  Please provide us your proposed disclosure.
2.We note you quantify and attribute the change in revenue between periods to the impact of
foreign currency exchange fluctuations throughout your MD&A.  Please tell us in detail
and revise future filings to clarify how you quantify the impact of foreign currency
exchange fluctuations.  Please consider providing us a simplified example showing the

 FirstName LastNameMark McGivney
 Comapany NameMarsh & McLennan Companies, Inc.
 March 16, 2023 Page 2
 FirstName LastName
Mark McGivney
Marsh & McLennan Companies, Inc.
March 16, 2023
Page 2
calculation.
Consolidated Balance Sheets, page 62
3.We note disclosure on page 70 related to presenting cash and cash equivalents held in a
fiduciary capacity as a contra-liability on your balance sheet, since they are not available
for corporate use.  Please tell us the accounting guidance you considered in determining
your presentation and specifically how you determined that cash and cash equivalents held
in a fiduciary capacity should not be presented as assets.
Note 1. Summary of Significant Accounting Policies, page 65
4.Noting the significance of the impact of foreign currency translation on your financial
results, please revise future filings to disclose your accounting policies used to translate
foreign currency statements.  Refer to ASC 830 for guidance.
            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.
            You may contact John Spitz at (202) 551-3484 or Michael Volley at (202) 551-3437 with
any questions.
Sincerely,
Division of Corporation Finance
Office of Finance