SecProbe.io

United States securities and exchange commission logo
December 23, 2022
Christa Davies
Chief Financial Officer
Aon plc
The Metropolitan Building
James Joyce Street
Dublin 1, Ireland D01 K0Y8
Re:Aon plc
Form 10-K for the Fiscal Year Ended December 31, 2021
Filed February 18, 2022
Form 10-Q for the Quarterly Period Ended September 30, 2022
Filed October 28, 2022
File No. 001-07933
Dear Christa Davies:
            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 the Fiscal Year Ended December 31, 2021
Notes to Consolidated Financial Statements
Note 1. Basis of Presentation
Revision of Previously Issued Financial Statements, page 59
1.We note your disclosure that you identified and corrected a presentation error related to
funds held on behalf of clients in the Consolidated Statements of Cash Flows.  Please
address the items below.
•Provide us with a full and detailed description of the error, including, but not limited
to, a discussion of who identified the error, when, and how, and whether it was the
result of any control deficiency.
•In your response to the above bullet, ensure you include a thorough discussion and

 FirstName LastNameChrista Davies
 Comapany NameAon plc
 December 23, 2022 Page 2
 FirstName LastName
Christa Davies
Aon plc
December 23, 2022
Page 2
description of the control deficiency to the extent one was identified, the Company's
evaluation of whether it was a control deficiency, significant deficiency, or material
weakness, and any remediation plans.  To the extent the Company concluded there
was not a control deficiency, tell us why.
•Provide us with your assessment of materiality supporting your conclusion that it was
immaterial.  Ensure that your response thoroughly addresses both qualitative and
quantitative factors as well as an objective assessment of materiality from the
perspective of a reasonable investor, including your consideration of guidance in
ASC 250, SAB 99, and management’s assessment of the design and effectiveness of
internal controls over financial reporting.
•Tell us how far you believe the errors go back and whether you quantified the impact
on periods prior to 2019.
Form 10-Q for the Quarterly Period Ended September 30, 2022
Management's Discussion and Analysis of Financial Condition and Results of Operations
Revenue, page 31
2.We note your disclosure on page 32 regarding AUM-based delegated investment
management revenue.  In future filings, please enhance your disclosures to more fully
explain AUM movements impacting your revenues, such as quantification of related
AUM size trends, explanation of AUM-based fee arrangements, and what is driving those
changes period-over-period.  In addition, clarify whether you hold any related assets under
management and, if so, quantify this and explain your responsibilities related to them.
            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 Cara Lubit at 202-551-5909 or Robert Klein at 202-551-3847 with any
questions.
Sincerely,
Division of Corporation Finance
Office of Finance