SEC Company Response from REINSURANCE GROUP OF AMERICA (RGA) — May 10, 2017
REINSURANCE GROUP OF AMERICA INC
Date: May 10, 2017 · CIK: 0000898174 · Accession: 0000898174-17-000018
AI Filing Summary & Sentiment
File numbers found in text: 001-11848
Referenced dates: May 3, 2017
Letter
VIA EDGAR Division of Corporation Finance United States Securities and Exchange Commission Reinsurance Group of America, Incorporated (the “Company”) Form 8-K dated April 27, 2017 Filed April 27, 2017 File No. 001-11848
Dear Mr. Rosenberg:
This letter is in response to the comment letter of the staff (the “Staff”) of the Securities and Exchange Commission dated May 3, 2017, regarding the above-referenced filing of the Company. This letter sets forth the comment from the Staff in the comment letter below in boldface and the Company’s response in ordinary type follows.
Exhibit 99.2
1.
You present a full non-GAAP income statement titled “consolidated adjusted operating income statements.” Please confirm you will discontinue this 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.
The Company acknowledges the Staff’s comment, and we confirm, that beginning with our next earnings release for the period ended June 30, 2017 we will discontinue the presentation of a full non-GAAP income statement.
* * * * *
The Company appreciates your prompt review and looks forward to hearing from you with respect to the foregoing response. If you have any questions or if you require any additional information with respect to this matter, please feel free to contact me via telephone at (636) 736-7243 or via email at jhayden@rgare.com.
Yours sincerely,
/s/ John W. Hayden
John W. Hayden
Senior Vice President - Controller
cc:
Todd C. Larson
Clifford R. Jenks, Esq.
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CORRESP 1 filename1.htm Document Reinsurance Group of America, Incorporated John W. Hayden Senior Vice President - Controller May 10, 2017 VIA EDGAR Mr. Jim B. Rosenberg Senior Assistant Chief Accountant Division of Corporation Finance United States Securities and Exchange Commission 100 F Street, N.E. Washington, DC 20549 Re: Reinsurance Group of America, Incorporated (the “Company”) Form 8-K dated April 27, 2017 Filed April 27, 2017 File No. 001-11848 Dear Mr. Rosenberg: This letter is in response to the comment letter of the staff (the “Staff”) of the Securities and Exchange Commission dated May 3, 2017, regarding the above-referenced filing of the Company. This letter sets forth the comment from the Staff in the comment letter below in boldface and the Company’s response in ordinary type follows. Exhibit 99.2 1. You present a full non-GAAP income statement titled “consolidated adjusted operating income statements.” Please confirm you will discontinue this 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. The Company acknowledges the Staff’s comment, and we confirm, that beginning with our next earnings release for the period ended June 30, 2017 we will discontinue the presentation of a full non-GAAP income statement. * * * * * The Company appreciates your prompt review and looks forward to hearing from you with respect to the foregoing response. If you have any questions or if you require any additional information with respect to this matter, please feel free to contact me via telephone at (636) 736-7243 or via email at jhayden@rgare.com. Yours sincerely, /s/ John W. Hayden John W. Hayden Senior Vice President - Controller cc: Todd C. Larson Clifford R. Jenks, Esq.