SEC Comment Letter for REINSURANCE GROUP OF AMERICA (RGA) — Sep 18, 2013
REINSURANCE GROUP OF AMERICA INC
Date: Sept. 18, 2013 · CIK: 0000898174 · Accession: 0000000000-13-051373
AI Filing Summary & Sentiment
File numbers found in text: 001-11848
Letter
September 1 8, 2013 Via E-mail Mr. Jack B. Lay Senior Executive Vice President and Chief Financial Officer Reinsurance Group of America , Inc. 1370 Timberlake Manor Parkway Chesterfield, MO 63017
Re: Reinsurance Group of America , Inc. Form 10-K for the Fiscal Year Ended December 31 , 2012 Filed March 1, 2013 File No . 001-11848
Dear M r. Lay:
We have reviewed your August 20, 2013 response to our August 8, 2013 letter and have the following comments.
Please respond to this letter within 10 business days by providing the requested information or by advising us when you will provide the requested response. If you do not believe a comment applies to your facts and circumstances, please tell us why in your response. Please furnish us a letter on EDGAR under the form type label CORRESP that keys your response to our comments.
After reviewing any information you provide in response to a comment , we may have additional comments.
Notes to the Consolidated Financial Statements
Note 4. Investments Mortgage Loans on Real Estate, page 101
1. Please refer to your response to our prior comment one and provide us revised proposed disclosure to be included in future filings, as applicable: Regarding “by type of credit loss” at the end of your proposed disclosure to the lead -in sentence to the table, it is not clear to what this refers . It seems that th is denotation may be unnecessary if the allowance follows the same method s of measuring credit loss as the mortgage loans. Regarding the line items “evaluated individually for credit losses” and “specific for credit losses” shown in the table, we believe that referring to these line items as loans impaired on an indivi dual loan basis and allowance for individually impaired loans, respectively, or something similar, would more aptly describe their nature .
Mr. Jack B. Lay Reinsurance Group of America, Inc. September 18, 2013 Page 2
Note 14. Collateral Finance Facility, page 137
2. Please refer to your response to prior comment two. Provide us a more robust response to our request in the last bullet of our comment that tells us the expected effects on your financial position and results of operations if you discontinue this strategy. In this regard, your response should tell us the aspec t(s) of and magnitude to your financial position and results of operations , or that you would not expect any material effects.
You may contact Christine Allen, Staff Accountant , at (202) 551 -3652 if you have questions regarding the comment s. In this regard, do not hesitate to contact me at (202) 551 - 3679.
Sincerely,
/s/ Jim B. Rosenberg
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September 1 8, 2013 Via E-mail Mr. Jack B. Lay Senior Executive Vice President and Chief Financial Officer Reinsurance Group of America , Inc. 1370 Timberlake Manor Parkway Chesterfield, MO 63017 Re: Reinsurance Group of America , Inc. Form 10-K for the Fiscal Year Ended December 31 , 2012 Filed March 1, 2013 File No . 001-11848 Dear M r. Lay: We have reviewed your August 20, 2013 response to our August 8, 2013 letter and have the following comments. Please respond to this letter within 10 business days by providing the requested information or by advising us when you will provide the requested response. If you do not believe a comment applies to your facts and circumstances, please tell us why in your response. Please furnish us a letter on EDGAR under the form type label CORRESP that keys your response to our comments. After reviewing any information you provide in response to a comment , we may have additional comments. Notes to the Consolidated Financial Statements Note 4. Investments Mortgage Loans on Real Estate, page 101 1. Please refer to your response to our prior comment one and provide us revised proposed disclosure to be included in future filings, as applicable: Regarding “by type of credit loss” at the end of your proposed disclosure to the lead -in sentence to the table, it is not clear to what this refers . It seems that th is denotation may be unnecessary if the allowance follows the same method s of measuring credit loss as the mortgage loans. Regarding the line items “evaluated individually for credit losses” and “specific for credit losses” shown in the table, we believe that referring to these line items as loans impaired on an indivi dual loan basis and allowance for individually impaired loans, respectively, or something similar, would more aptly describe their nature . Mr. Jack B. Lay Reinsurance Group of America, Inc. September 18, 2013 Page 2 Note 14. Collateral Finance Facility, page 137 2. Please refer to your response to prior comment two. Provide us a more robust response to our request in the last bullet of our comment that tells us the expected effects on your financial position and results of operations if you discontinue this strategy. In this regard, your response should tell us the aspec t(s) of and magnitude to your financial position and results of operations , or that you would not expect any material effects. You may contact Christine Allen, Staff Accountant , at (202) 551 -3652 if you have questions regarding the comment s. In this regard, do not hesitate to contact me at (202) 551 - 3679. Sincerely, /s/ Jim B. Rosenberg Jim B. Rosenberg Senior Assistant Chief Accountant