SEC Comment Letter 0000000000-24-002978 to Arthur J. Gallagher & Co. (AJG) (CIK 0000354190) (AJG)
Arthur J. Gallagher & Co. (AJG) (CIK 0000354190)
Date: March 19, 2024 · CIK: 0000354190 · Accession: 0000000000-24-002978
AI Filing Summary & Sentiment
File numbers found in text: 001-09761
Letter
United States securities and exchange commission logo March 19, 2024 Douglas K. Howell Chief Financial Officer Arthur J. Gallagher & Co. 2850 Golf Road Rolling Meadows, IL 60008-4050 Re:Arthur J. Gallagher & Co. Form 10-K for the Fiscal Year Ended December 31, 2023 File No. 001-09761 Dear Douglas K. Howell: 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 the Fiscal Year Ended December 31, 2023 Notes to Consolidated Financial Statements 5. Change in Presentation of Fiduciary Assets and Liabilities, page 89 1.We note your disclosure that you revised your balance sheet and statement of cash flows presentation to separately identify and present fiduciary assets and liabilities and that you also made certain revisions to fiduciary balances related to the former Willis Re operations from gross to net presentation to align with your accounting policy and presentation. For each change and revision reflected in the financial statements, please address the items below. •Clarify whether you concluded that your prior presentation (e.g., gross to net, statement of cash flow classification, etc.) was an error and how you considered ASC 250 in your determination. •To the extent applicable, provide us with a detailed description of any error(s), including but not limited to who identified them, when and how, whether they were the result of control deficiencies, as well as your assessment of materiality, individually and in the aggregate, that addresses both qualitative and quantitative
FirstName LastNameDouglas K. Howell Comapany NameArthur J. Gallagher & Co. March 19, 2024 Page 2 FirstName LastName Douglas K. Howell Arthur J. Gallagher & Co. March 19, 2024 Page 2 factors and consideration of guidance in ASC 250, SAB 99, and management's assessment of design and effectiveness of ICFR. •Provide us with an accounting analysis, citing authoritative literature, explaining your presentation before and after implementing these changes to your presentation. For example, explain why net change in fiduciary assets and liabilities appears to have moved from operating activities to financing activities within the statement of cash flows. 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 Cara Lubit at 202-551-5909 or Robert Klein at 202-551-3847 with any questions. Sincerely, Division of Corporation Finance Office of Finance
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United States securities and exchange commission logo
March 19, 2024
Douglas K. Howell
Chief Financial Officer
Arthur J. Gallagher & Co.
2850 Golf Road
Rolling Meadows, IL 60008-4050
Re:Arthur J. Gallagher & Co.
Form 10-K for the Fiscal Year Ended December 31, 2023
File No. 001-09761
Dear Douglas K. Howell:
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 the Fiscal Year Ended December 31, 2023
Notes to Consolidated Financial Statements
5. Change in Presentation of Fiduciary Assets and Liabilities, page 89
1.We note your disclosure that you revised your balance sheet and statement of cash flows
presentation to separately identify and present fiduciary assets and liabilities and that you
also made certain revisions to fiduciary balances related to the former Willis Re
operations from gross to net presentation to align with your accounting policy and
presentation. For each change and revision reflected in the financial statements, please
address the items below.
•Clarify whether you concluded that your prior presentation (e.g., gross to net,
statement of cash flow classification, etc.) was an error and how you considered ASC
250 in your determination.
•To the extent applicable, provide us with a detailed description of any error(s),
including but not limited to who identified them, when and how, whether they were
the result of control deficiencies, as well as your assessment of materiality,
individually and in the aggregate, that addresses both qualitative and quantitative
FirstName LastNameDouglas K. Howell
Comapany NameArthur J. Gallagher & Co.
March 19, 2024 Page 2
FirstName LastName
Douglas K. Howell
Arthur J. Gallagher & Co.
March 19, 2024
Page 2
factors and consideration of guidance in ASC 250, SAB 99, and management's
assessment of design and effectiveness of ICFR.
•Provide us with an accounting analysis, citing authoritative literature, explaining your
presentation before and after implementing these changes to your presentation. For
example, explain why net change in fiduciary assets and liabilities appears to have
moved from operating activities to financing activities within the statement of cash
flows.
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 Cara Lubit at 202-551-5909 or Robert Klein at 202-551-3847 with any
questions.
Sincerely,
Division of Corporation Finance
Office of Finance