SEC Comment Letter for REINSURANCE GROUP OF AMERICA (RGA) — Oct 17, 2013
REINSURANCE GROUP OF AMERICA INC
Date: Oct. 17, 2013 · CIK: 0000898174 · Accession: 0000000000-13-057041
AI Filing Summary & Sentiment
File numbers found in text: 001-11848
Letter
Octob er 16, 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 October 1 , 2013 response to our September 18 , 2013 letter and have the following comment .
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 the 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 comment .
After reviewing any information you provide in response to the comment , we may have additional comments.
Notes to the Consolidated Financial Statements Note 14. Collateral Finance Facility, page 137
1. We have read your response to prior comment two and request that you please address the following: In your August 20, 2013 respon se, you refer to MD&A disclosure of the possible significant reduction to RGA Reinsurance’s statutory capital if the required collateral necessary to support its statutory capital is not provided. Provide us proposed disclosure to be included in MD&A in f uture periodic reports that explains the consequences and expected effects to the Company’s consolidated future financial position and results of operations regarding the uncertainty of RGA Reinsurance’s statutory capital. In your October 1, 2013 respons e, you indicate that discontinuing your captive strategy could increase your overall costs. Additionally, you indicate that your ability to reinsure and to deploy excess capital could be adversely affected which could adversely impact your competitive pos ition and results of operations. Provide us proposed MD&A disclosure that explains the consequences of the uncertainly regarding continuing your
Mr. Jack B. Lay Reinsurance Group of America, Inc. October 16, 2013 Page 2
captive strategy, and its expected effects on the Company’s consolidated future operations and financial posit ion. To the extent that you do not believe that disclosure is required, please provide us your analysis of Section 501.02 of the Financial Reporting Codification regarding prospective information that supports your conclusion. In particular, address th e two assessments management must make regarding a known trend, demand, commitment, event or uncertainty.
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
Show Raw Text
Octob er 16, 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 October 1 , 2013 response to our September 18 , 2013 letter and have the following comment . 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 the 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 comment . After reviewing any information you provide in response to the comment , we may have additional comments. Notes to the Consolidated Financial Statements Note 14. Collateral Finance Facility, page 137 1. We have read your response to prior comment two and request that you please address the following: In your August 20, 2013 respon se, you refer to MD&A disclosure of the possible significant reduction to RGA Reinsurance’s statutory capital if the required collateral necessary to support its statutory capital is not provided. Provide us proposed disclosure to be included in MD&A in f uture periodic reports that explains the consequences and expected effects to the Company’s consolidated future financial position and results of operations regarding the uncertainty of RGA Reinsurance’s statutory capital. In your October 1, 2013 respons e, you indicate that discontinuing your captive strategy could increase your overall costs. Additionally, you indicate that your ability to reinsure and to deploy excess capital could be adversely affected which could adversely impact your competitive pos ition and results of operations. Provide us proposed MD&A disclosure that explains the consequences of the uncertainly regarding continuing your Mr. Jack B. Lay Reinsurance Group of America, Inc. October 16, 2013 Page 2 captive strategy, and its expected effects on the Company’s consolidated future operations and financial posit ion. To the extent that you do not believe that disclosure is required, please provide us your analysis of Section 501.02 of the Financial Reporting Codification regarding prospective information that supports your conclusion. In particular, address th e two assessments management must make regarding a known trend, demand, commitment, event or uncertainty. 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