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June 20, 2024

VIA EDGAR

Securities and Exchange Commission

Division of Corporation Finance

Office of Finance

100 F. Street, N.E.

Washington, D. C. 20549

Re: Globe Life Inc.

Form 10-K for Fiscal Year Ended December 31, 2023

File No. 001-08052

Ladies and Gentlemen,

Please find below our response to the comments on Globe Life Inc.’s Form 10-K for the fiscal year ended December 31, 2023, set forth in your letter dated June 6, 2024. We appreciate the opportunity to provide information in response to your questions.

Below we have listed your comments in bold font and our response following. For items which we are presenting future proposed disclosure, we have highlighted those in italics and underlined font.

Comment:

Business, page 1

1.    Please revise future filings in this section or in MD&A to explain the typical timing of premium payments (e.g., weekly, monthly, annually) and the typical method of payment (auto-draft, check, cash, etc.) for life and health policies. Please provide us your proposed disclosure.

Response:

Globe Life Inc. (the “Company,” “we,” “our,” “us”) premiums are typically paid to us on a monthly basis by auto-bank draft for both our life and health segments. We accept other forms of payment, which comprise a smaller portion of premium payments, such as check, credit card, and worksite payroll deduction,

We propose to include the following disclosure in Management’s Discussion and Analysis (MD&A) Results of Operations as noted in our next Form 10-Q filing.

Approximately 90% of our premiums are collected monthly; however, other premium payment options such as quarterly and annual are offered by the Company and may be elected by the policyholder. The majority of premiums are paid by way of automatic draft or electronic payment from our policyholders and to a lesser extent from other payment methods such as check, credit card and worksite payroll deduction.

Comment:

Legal Proceedings, page 17

2.    Please ensure you describe in future filings any material pending legal proceedings including proceedings contemplated by governmental authorities. Refer to Item 103 of Regulation S-K for guidance.

Response:

We acknowledge the requirements of Item 103 of Regulation S-K. We disclose all pending material legal proceedings, including proceedings contemplated by governmental authorities, in accordance with Item 103 of Regulation S-K and will continue to do so in future filings.

Comment:

Management’s Discussion and Analysis of Financial Condition and Results of Operations, page 21

3.    Given the material impact on financial results from lapses, please revise future filings to provide additional quantified information regarding lapses for each period presented, discuss/quantify the impact on revenue and other relevant financial metrics and discuss relevant trends. Please provide us your proposed disclosure.

Response:

Lapses are an important element within our business and policy liability valuation as disclosed within our 2023 Form 10-K, notably within the following disclosures:

Risk Factors—Industry Risks (page 11);

Management’s Discussion and Analysis (page 21);

Critical Accounting Policies (page 48); and

Note 1—Significant Accounting Policies and Note 6—Policy Liabilities within the Notes to the Consolidated Financial Statements (page 62 and 96).

As disclosed in our Critical Accounting Policies within Item 7. Management’s Discussion and Analysis in our 2023 Form 10-K, “The Company reviews, and updates as necessary, its cash flow assumptions (mortality, morbidity, and lapses) used to calculate the change in the liability for future policy benefits at least annually. These cash flow assumptions are reviewed at the same time every year, or more frequently, if suggested by experience. If cash flow assumptions are changed, the net premium ratio is recalculated from the original issue date, or the Transition Date, using actual experience and projected future cash flows. As cash flow assumptions are changed, the liability for future policy benefits is adjusted with changes recognized in policyholder benefits on the Consolidated Statements of Operations.”

There are two components of remeasurement gain (loss): (1) Experience - remeasurement gain (loss) resulting from the effect of actual variances from expected experience and (2) Assumption Unlocking - remeasurement gain (loss) resulting from the effect of changes in cash flow assumptions on future cash flows. We record the remeasurement gain (loss) resulting from the effect of actual variances from expected experience on a quarterly basis. The effect of changes in assumptions on future cash flows is recorded at least annually, as described above and results from updates to mortality, morbidity, and lapse assumptions. Disclosed in Note 6—Policy Liabilities within the Notes to the Consolidated Financial Statements on page 103 in our 2023 Form 10-K.

An analysis of the table summarizing the remeasurement gain (loss) disclosed in Note 6—Policy Liabilities within the Notes to the Consolidated Financial Statements on page 103 in our 2023 Form 10-K, demonstrates that our actual experience has not deviated significantly from our expectation with total remeasurement gain (loss) representing (0.21%), 0.18%, and 0.05% of the liability for future policy benefits at current discount rates as of December 31, 2023, 2022, and 2021 respectively. The referenced disclosure is as follows:

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The following table includes the total remeasurement gain (loss), bifurcated between the gain or loss due to the difference between actual and expected experience and the difference due to assumption updates, for each of the three years-ended December 31, 2023.

  2023  2022  2021

Life Remeasurement Gain (Loss)—Experience

American Income  $ 9,430  $ 1,965  $ (2,008)

Direct to Consumer  12,201  (2,243)  (4,782)

Liberty National  5,013  (1,348)  (865)

Other  4,760  1,354  664

  31,404  (272)  (6,991)

Life Remeasurement Gain (Loss)—Assumption Unlocking

American Income  308  (8,707)  (750)

Direct to Consumer  1,763  (25,334)  (2,242)

Liberty National  (1,248)  (7,872)  (733)

Other  (2,836)  (5,241)  (350)

  (2,013)  (47,154)  (4,075)

Total Life Remeasurement Gain (Loss)

  $ 29,391  $ (47,426)  $ (11,066)

Health Remeasurement Gain (Loss)—Experience

United American  $ (134)  $ 3,502  $ (2,343)

Family Heritage  4,638  2,395  594

Liberty National  628  1,406  304

American Income  1,461  (2,545)  199

Direct to Consumer  23  148  16

  6,616  4,906  (1,230)

Health Remeasurement Gain (Loss)—Assumption Unlocking

United American  762  (626)  —

Family Heritage  2,173  6,283  —

Liberty National  2,171  1,463  —

American Income  119  3,615  —

Direct to Consumer  8  (80)  —

  5,233  10,655  —

Total Health Remeasurement Gain (Loss)

  $ 11,849  $ 15,561  $ (1,230)

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We include a schedule titled Life Annualized Premium in Force Rollforward and Lapse Rates on our website, in the section Financial Reports and Other Financial Information, Life Premiums Inforce and Lapse Rates, which includes lapse information by division (American Income Life, Direct to Consumer, Liberty National, Other). We have inserted an excerpt of American Income as an example of that information below:

GLOBE LIFE INC.

Life Annualized Premium In Force(1) Rollforward and Lapse Rates

(Unaudited)

(Dollar amounts in thousands)

 March 31,
2024  December 31,
2023  September 30,
2023  June 30,
2023  March 31,
2023

 Amount  Lapse Rate  Amount  Lapse Rate  Amount  Lapse Rate  Amount  Lapse Rate  Amount  Lapse Rate

American Income Life Division

Beginning of quarter $ 1,654,197      $ 1,635,206      $ 1,613,415      $ 1,580,423      $ 1,553,003

Net sales 97,195      76,323      81,066      81,940      83,329

Lapses

First year (25,714)   9.60  %  (23,242)   8.71  %  (22,229)   8.50  %  (20,233)   7.93  %  (21,793)   8.92  %

Renewal year (35,186)   2.57  %  (36,229)   2.67  %  (33,207)   2.48  %  (32,381)   2.45  %  (32,016)   2.46  %

 (60,900)   3.72  %  (59,471)   3.67  %  (55,436)   3.46  %  (52,614)   3.34  %  (53,809)   3.48  %

Deaths and other(2)

 (4,639)     2,139      (3,839)     3,666      (2,100)

End of quarter 1,685,853      1,654,197      1,635,206      1,613,415      1,580,423

(1)    Annualized premium in force is defined as the premium income that would be received over the following twelve months at any given date on all active policies if those policies remain in force throughout the twelve-month period. Annualized premium in force is an indicator of potential growth in premium revenue.

(2)    Include foreign exchange adjustments, source data adjustments, changes in coverage and timing differences.

We would respectfully request to keep this detailed information of lapse rates within the Financial Reports and Other Financial Information on our website as additional information of our business data. While we believe this data is informative, we do not believe it is significant to the understanding of our financial results due to the fact that lapses are a component of the recorded liability for future policy benefits. Deviations in actual experience from our estimated assumptions that are significant are included in the discussion relative to understanding our financial results. We discuss material impacts from our assumptions and any trends that would impact our financial results in Results of Operations within Item 7. Management’s Discussion and Analysis and in Note 6—Policy Liabilities within the Notes to the Consolidated Financial Statements in our 2023 Form 10-K.

We propose to include the following disclosure within our MD&A discussion of results in our next Form 10-Q filing:

If actual mortality, morbidity, and lapse experience equals our expected assumptions used in the development of our liability for future policy benefits, there would be no impact to our financial results. Actual experience can have a material impact on financial results to the extent it significantly deviates from the expected assumptions which are used to develop our estimates of the liability for future policy benefits (LFPB) and amortization of the deferred acquisition cost asset (DAC). For example, deviations in actual versus expected lapses in the early policy years tend to have a larger impact on DAC amortization than LFPB change in reserves. Conversely, deviations in actual versus expected lapses in the later policy years typically have a larger impact on LFPB change in reserves than DAC amortization. This is due to the release of DAC and LFPB where DAC capitalization in earlier years is amortizing over time and the LFPB is increasing over time as the policy stays inforce. Disaggregated rollforwards of our present value of expected future net premiums and our expected future policy benefits are presented within Note 6—Policy Liabilities, which include disclosure of remeasurement gain (loss) for the effect of actual variances from expected experience and the changes in assumptions (mortality, morbidity, and lapses) on future cash flows.

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Comment:

4.    We note your discussion on page 26 related to cancellations in the first thirty days after issuance of a policy. Please revise future filings to clarify if cancellations are included in lapses. If not and if material, please revise future filings to disclose cancellations by distribution channel for each period presented and discuss relevant trends. Please provide us your proposed disclosure.

Response:

Cancellations are not included in lapses. Cancellations are associated with a policy cancelled during the underwriting process or free-look period. Cancellations are made at the request of an applicant when an application is withdrawn or exercising a free-look provision or at the discretion of the Company when an applicant does not meet our underwriting criteria. Cancellations are not material to the Company’s consolidated financial statements and as such, we believe no additional disclosures are necessary.

We propose to include the following disclosure within MD&A in the section where we define the three measures we use relative to evaluating premium growth and sales in our next Form 10-Q filing:

Cancellations are not included in lapses.

Comment:

Summary of Operations, page 23

5.    We note your discussion of net sales on page 26. In future filings, please explain why management considers net sales a better indicator of the rate of premium growth as compared to annualized premium issued. Please provide us your proposed disclosure.

Response:

Net sales within the insurance industry is the typical measure used as an indicator of operating performance. Net sales are calculated as annualized premium issued, net of cancellations. In the case of Direct to Consumer, net sales is annualized premium issued after any introductory offer period.

We consider net sales a better indicator of the rate of premium growth due to the exclusion of cancellations which do not contribute to premium revenue.

We propose to include the following disclosure within MD&A in our next Form 10-Q filing:

Net sales are calculated as annualized premium issued, net of cancellations in the first thirty days after issue, except in the case of Direct to Consumer, where net sales is annualized premium issued at the time the first full premium is paid after any introductory offer period has expired. Management considers net sales to be a better indicator of the rate of premium growth than annualized premium issued since annualized premium issued excludes cancellations, and cancellations do not contribute to premium income.

Comment:

6.    In future filings, please revise your discussion of net sales and first-year collected premium on page 25 to more clearly explain why first-year collected premium is significantly less than net sales. Please provide us your proposed disclosure.

Response:

We propose to include the following disclosure within MD&A in our next Form 10-Q filing:

First-year collected premium is defined as the premium collected during the reporting period for all policies in their first policy year. First-year collected premium takes lapses into account in the first year when lapses are more likely

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to occur, and thus is a useful indicator of how much new premium is expected to be added to premium income in the future. First-year collected premiums are lower than net sales over the prior 12 months because premiums are not collected on lapsed policies after the date of lapse.

Comment:

Direct to Consumer Division, page 26

7.    Please revise future filings to provide relevant information related to the introductory offer period. If material, please revise to clarify the impact of introductory offer periods on revenue recognition in your accounting policy disclosure. Please provide us your proposed disclosure.

Response:

We have two types of introductory offers that we offer to customers. One is a “send no money” where the customer completes an application form; when the application is approved and the first month’s premium is received, the policy is in effect. The second introductory offer is up to one month of coverage for a reduced premium of $1. We record revenue at the time the premium is due, and the policy is issued in both types of introductory offers. The impact of the introductory offer period is not material to the Company’s consolidated financial statements.

We propose to include the following disclosure within MD&A in our next Form 10-Q filing:

Net sales are calculated as annualized premium issued, net of cancellations in the first thirty days after issue, except in the case of Direct to Consumer, where net sales is annualized premium issued at the time the first full premium is paid after any introductory offer period (typically 1 month) has expired. Management considers net sales to be a better indicator of the rate of premium growth than annualized premium issued