SEC Comment Letter 0000000000-24-008459 to FORTITUDE LIFE INSURANCE & ANNUITY CO (CIK 0000881453)
FORTITUDE LIFE INSURANCE & ANNUITY CO (CIK 0000881453)
Date: July 25, 2024 · CIK: 0000881453 · Accession: 0000000000-24-008459
AI Filing Summary & Sentiment
File numbers found in text: 333-44202
Letter
July 25, 2024 Kai Talarek Chief Financial Officer Fortitude Life Insurance & Annuity Company Ten Exchange Plaza Suite 2210 Jersey City, New Jersey 07302 Re:Fortitude Life Insurance & Annuity Company Form 10-K for the Fiscal Year Ended December 31, 2023 File No. 333-44202 Dear Kai Talarek: 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 Financial Statements 2. Significant Accounting Policies and Pronouncements Effective ASUs as of December 31, 2023, page 61 1.We note your disclosure that the adoption of ASU 2018-12 is not applicable due to your election to adopt the fair value option. Please tell us and revise your disclosures, in future filings, to further describe the targeted improvements of the standard and why it is not applicable. In your response, provide us with an explanation for each of the separate improvements, including the disclosure improvements such as ASC 944-80-50-2, contemplated in the standard and how you considered its applicability in your financial statements. 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.
July 25, 2024 Page 2 Please contact Marc Thomas at 202-551-3452 or Robert Klein at 202-551-3847 with any questions. Sincerely, Division of Corporation Finance Office of Finance
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July 25, 2024
Kai Talarek
Chief Financial Officer
Fortitude Life Insurance & Annuity Company
Ten Exchange Plaza
Suite 2210
Jersey City, New Jersey 07302
Re:Fortitude Life Insurance & Annuity Company
Form 10-K for the Fiscal Year Ended December 31, 2023
File No. 333-44202
Dear Kai Talarek:
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 Financial Statements
2. Significant Accounting Policies and Pronouncements
Effective ASUs as of December 31, 2023, page 61
1.We note your disclosure that the adoption of ASU 2018-12 is not applicable due to your
election to adopt the fair value option. Please tell us and revise your disclosures, in future
filings, to further describe the targeted improvements of the standard and why it is not
applicable. In your response, provide us with an explanation for each of the separate
improvements, including the disclosure improvements such as ASC 944-80-50-2,
contemplated in the standard and how you considered its applicability in your financial
statements.
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.
July 25, 2024
Page 2
Please contact Marc Thomas at 202-551-3452 or Robert Klein at 202-551-3847 with any
questions.
Sincerely,
Division of Corporation Finance
Office of Finance