SEC Comment Letter for REINSURANCE GROUP OF AMERICA (RGA) — May 2, 2018
REINSURANCE GROUP OF AMERICA INC
Date: May 2, 2018 · CIK: 0000898174 · Accession: 0000000000-18-013593
AI Filing Summary & Sentiment
File numbers found in text: 001-11848
Letter
May 2, 2018 Todd C. Larson Senior Executive Vice President and Chief Financial Officer Reinsurance Group of America, Inc. 16600 Swingley Ridge Road Chesterfield, MO 63017 Re:Reinsurance Group of America, Inc. Form 10-K for the Fiscal Year Ended December 31, 2017 Filed February 27, 2018 File No. 001-11848 Dear Mr. Larson: 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 Year Ended December 31, 2017 Notes to Consolidated Financial Statements Note 16. Short Duration contracts, page 148 1.Please provide us the information required by ASC 944-40-50-3 separately by short duration and long duration contracts, and tell us why you did not include this information in the notes to consolidated financial statements. 2.Please refer to the reconciliation of the net incurred and paid claims development tables to the liability for claims and claim adjustment expense in the consolidated balance sheet as of December 31, 2017. Regarding the adjustment "effect of discounting and unallocated claims adjustment expense," provide us the amount related to unallocated claims adjustment expense and tell us why this adjustment is a deduction in the reconciliation.
FirstName LastNameTodd C. Larson Comapany NameReinsurance Group of America, Inc. June 16, 2017 Page 2 FirstName LastName Todd C. Larson Reinsurance Group of America, Inc. May 2, 2018 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 Sasha Parikh at 202-551-3627 or Jim Rosenberg at 202-551-3679 with any questions. Division of Corporation Finance Office of Healthcare & Insurance
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May 2, 2018
Todd C. Larson
Senior Executive Vice President and Chief Financial Officer
Reinsurance Group of America, Inc.
16600 Swingley Ridge Road
Chesterfield, MO 63017
Re:Reinsurance Group of America, Inc.
Form 10-K for the Fiscal Year Ended December 31, 2017
Filed February 27, 2018
File No. 001-11848
Dear Mr. Larson:
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 Year Ended December 31, 2017
Notes to Consolidated Financial Statements
Note 16. Short Duration contracts, page 148
1.Please provide us the information required by ASC 944-40-50-3 separately by short
duration and long duration contracts, and tell us why you did not include this information
in the notes to consolidated financial statements.
2.Please refer to the reconciliation of the net incurred and paid claims development tables to
the liability for claims and claim adjustment expense in the consolidated balance sheet as
of December 31, 2017. Regarding the adjustment "effect of discounting and unallocated
claims adjustment expense," provide us the amount related to unallocated claims
adjustment expense and tell us why this adjustment is a deduction in the reconciliation.
FirstName LastNameTodd C. Larson
Comapany NameReinsurance Group of America, Inc.
June 16, 2017 Page 2
FirstName LastName
Todd C. Larson
Reinsurance Group of America, Inc.
May 2, 2018
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 Sasha Parikh at 202-551-3627 or Jim Rosenberg at 202-551-3679 with
any questions.
Division of Corporation Finance
Office of Healthcare & Insurance