SEC Comment Letter 0000000000-23-007430 to Equitable Financial Life Insurance Co (CIK 0000727920)
Equitable Financial Life Insurance Co (CIK 0000727920)
Date: July 12, 2023 · CIK: 0000727920 · Accession: 0000000000-23-007430
AI Filing Summary & Sentiment
File numbers found in text: 000-20501
Letter
United States securities and exchange commission logo July 12, 2023 Robin M. Raju Chief Financial Officer Equitable Financial Life Insurance Company 1290 Avenue of the Americas New York, New York 10104 Re:Equitable Financial Life Insurance Company Form 10-K for the Fiscal Year Ended December 31, 2022 Filed February 21, 2023 File No. 000-20501 Dear Robin M. Raju: 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, 2022 Notes to Consolidated Financial Statements 3) Investments, page 85 1.We note your disclosure on page 90 stating that the Company did not intend to sell the securities nor will likely be required to dispose of the securities with unrealized losses in your available for sale portfolio before the anticipated recovery of their remaining amortized cost basis. However, we also note your disclosure on page 133 stating that due to the potential need for liquidity in a macro stress environment, the Company does not currently have the intent to hold the underlying securities to recovery as part of your accounting for the deferred tax assets and related valuation allowance associated with these securities. Please clarify and reconcile how these disclosures are consistent with each other, and explain your related accounting conclusions for each. Cite the specific authoritative literature considered for your accounting conclusions.
FirstName LastNameRobin M. Raju Comapany NameEquitable Financial Life Insurance Company July 12, 2023 Page 2 FirstName LastName Robin M. Raju Equitable Financial Life Insurance Company July 12, 2023 Page 2 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 Lory Empie, Staff Accountant, at 202-551-3714 or Robert Klein, Accounting Branch Chief, 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
July 12, 2023
Robin M. Raju
Chief Financial Officer
Equitable Financial Life Insurance Company
1290 Avenue of the Americas
New York, New York 10104
Re:Equitable Financial Life Insurance Company
Form 10-K for the Fiscal Year Ended December 31, 2022
Filed February 21, 2023
File No. 000-20501
Dear Robin M. Raju:
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, 2022
Notes to Consolidated Financial Statements
3) Investments, page 85
1.We note your disclosure on page 90 stating that the Company did not intend to sell the
securities nor will likely be required to dispose of the securities with unrealized losses in
your available for sale portfolio before the anticipated recovery of their remaining
amortized cost basis. However, we also note your disclosure on page 133 stating that due
to the potential need for liquidity in a macro stress environment, the Company does not
currently have the intent to hold the underlying securities to recovery as part of your
accounting for the deferred tax assets and related valuation allowance associated with
these securities. Please clarify and reconcile how these disclosures are consistent with
each other, and explain your related accounting conclusions for each. Cite the specific
authoritative literature considered for your accounting conclusions.
FirstName LastNameRobin M. Raju
Comapany NameEquitable Financial Life Insurance Company
July 12, 2023 Page 2
FirstName LastName
Robin M. Raju
Equitable Financial Life Insurance Company
July 12, 2023
Page 2
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 Lory Empie, Staff Accountant, at 202-551-3714 or Robert Klein,
Accounting Branch Chief, at 202-551-3847 with any questions.
Sincerely,
Division of Corporation Finance
Office of Finance