SEC Comment Letter for REINSURANCE GROUP OF AMERICA (RGA) — May 3, 2017
REINSURANCE GROUP OF AMERICA INC
Date: May 3, 2017 · CIK: 0000898174 · Accession: 0000000000-17-015540
AI Filing Summary & Sentiment
Letter
Mail Stop 4546 May 3 , 2017 VIA E -mail Mr. Todd C. Larson Senior Executive Vice President Finance & Chief Financial Officer Reinsurance Group of America , Inc. 16600 Swingley Ridge Road Chesterfield, MI 63017
Re: Reinsurance Group of America , Inc. Form 8-K dated April 27 , 2017 Filed April 27 , 2017 File No. 001 -11848
Dear Mr. Larson :
We have limited our review of your filing to the issue we have addressed in our comment .
Please respond to the comment within ten busine ss days by providing the requested information or advis e us as soon as possible when you will respond. If you do not believe our comment appl ies to your facts and circumstances, please tell us why in your r esponse.
After reviewing your response to the comment, we may have additional comments.
Exhibit 99.2
1. You present a full non -GAAP income statement titled “ consolidated adjusted operating income statements.” Please confirm that you will discontinue th is presentation of a full non-GAAP income statement beginning with your next earnings release. See Question 102.10 of the updated Non -GAAP Compliance and Disclosure Interpretations issued on May 17, 2016.
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.
Mr. Todd C. Larson Reinsurance Group of America , Inc. May 3 , 2017 Page 2
You may contact Senior Staff Accountants Christine Allen Torney at (202) 551 -3652 or Vanessa Robertson at (202) 551 -3649 with any questions . In this regard, do not hesitate to contact me at (202) 551 -3679.
Sincerely,
/s/ Jim B. Rosenberg
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Mail Stop 4546
May 3 , 2017
VIA E -mail
Mr. Todd C. Larson
Senior Executive Vice President Finance &
Chief Financial Officer
Reinsurance Group of America , Inc.
16600 Swingley Ridge Road
Chesterfield, MI 63017
Re: Reinsurance Group of America , Inc.
Form 8-K dated April 27 , 2017
Filed April 27 , 2017
File No. 001 -11848
Dear Mr. Larson :
We have limited our review of your filing to the issue we have addressed in our comment .
Please respond to the comment within ten busine ss days by providing the requested
information or advis e us as soon as possible when you will respond. If you do not believe our
comment appl ies to your facts and circumstances, please tell us why in your r esponse.
After reviewing your response to the comment, we may have additional comments.
Exhibit 99.2
1. You present a full non -GAAP income statement titled “ consolidated adjusted operating
income statements.” Please confirm that you will discontinue th is presentation of a full
non-GAAP income statement beginning with your next earnings release. See Question
102.10 of the updated Non -GAAP Compliance and Disclosure Interpretations issued on
May 17, 2016.
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.
Mr. Todd C. Larson
Reinsurance Group of America , Inc.
May 3 , 2017
Page 2
You may contact Senior Staff Accountants Christine Allen Torney at (202) 551 -3652 or
Vanessa Robertson at (202) 551 -3649 with any questions . 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
Office of Healthcare and Insurance