SEC Comment Letter for METLIFE (MET) — Mar 9, 2007
METLIFE INC
Date: March 9, 2007 · CIK: 0001099219 · Accession: 0000000000-07-012357
AI Filing Summary & Sentiment
File numbers found in text: 001-15787
Letter
Mail Stop 6010 Via Facsimile and U.S. Mail September 25, 2006 Mr. C. Robert Henrikson Chairman, President and Chief Executive Officer MetLife, Inc. 200 Park Avenue New York, New York 10166-0188
Re: MetLife, Inc. Form 10-K for fiscal year ended December 31, 2005 File No. 001-15787
Dear Mr. Henrikson:
We have limited our review of your filing to those issues we have addressed in our comments. In our comments, we ask you to provide us with information so we may better understand your disclosure. After re viewing this information, we may raise additional comments.
Please understand that the purpose of our re view process is to assist you in your compliance with the applicable disclosure requirements and to enhance the overall disclosure in your filing. We look forward to working with you in these respects. We welcome any questions you may have about our comments or any other aspect of our review. Feel free to call us at the telephone numbers listed at the end of this letter.
Form 10-K for fiscal year ended December 31, 2005
Managements’ Discussion and Analysis of Fi nancial Condition and Results of Operations Summary of Critical Acc ounting Estimates, page 60
1. We believe your disclosure could be impr oved to better explain the judgments and uncertainties in applying critical ac counting estimates for DAC and VOBA and the likelihood that materially different amounts would be reported under different conditions or using different assumptions. Please provide us in disclosure-type format the financial statement impact that reasonably likely changes in key assumptions underlying the December 31, 2005 estimates may have on financial position and results of operations. Refer to Section V of Financial Reporting Release No. 72.
Mr. C. Robert Henrikson MetLife, Inc. September 25, 2006 Page 2
Discussion of Results, page 67
2. Given the apparent significance of “interes t spreads” to your operating results for the institutional and individual segments, we believe that your disclosure could be improved. Please provide to us, in disclosure-type format, the following information for each of these segments.
• Quantify the dollar impact on operating results that corresponds to the percentage “interest spread” for each period presented. • Describe how you compute “yield on invested assets” and quantify the resulting dollar amount used to determine the “interest spread” for each period presented. • Describe how you compute “interest rate used to credit on certain liabilities” and quantify the resulting dollar amount used to determine the “interest spread” for each period presented. • Describe the factors that you considered in determining the expected range for “interest spreads” for each peri od presented. Explain why you used different “interest spreads” for 2004 in your comparisons of Institutional segment operating results for 2005/2004 and 2004/2003. • Explain more specifically the factor s underlying the change in “interest spread” and the variance between the expected and actual spreads for each period presented. We note that for n on-medical health & other business, the actual spread was 3.38% for 2005 and 3.06% for 2004 as compared to the expected spread range of 1.3 to 1.6% at December 31, 2005 and 1.3 to 1.5% at December 31, 2004.
Liquidity and Capital Resources
Contractual Obligations, page 94
3. You state that “lia bilities for future policy be nefits of $82.4 billion and policyholder account balances of $113.4 b illion both at December 31, 2005 have been excluded from the table” because in general the insurable event (e.g. death or disability) or triggering event has not yet occurred. However, you also make extensive use of asset/lia bility matching processes, whereby you “regularly reevaluate estimates used in determin ing the approximate amounts and timing of payments to or on behalf of policy hol ders for insurance liabilities.” These capabilities appear to indicate that you regularly estimate the information described in Item 303 (a) (5) of Regulati on S-K. Please provide us a revised table including estimates for the amount and timi ng of payments related to the excluded amounts or explain more specifically for each product line why you are unable to provide this information in the ta ble of contractual obligations. * * * *
Mr. C. Robert Henrikson MetLife, Inc. September 25, 2006 Page 3 Please respond to these comments within 10 business days or tell us when you will provide us with a response. Your letter should key your responses to our comments. Detailed letters greatly facil itate our review. Please file your letter on EDGAR under the form type label CORRESP.
We urge all persons who are responsible for the accuracy and adequacy of the disclosure in the filing to be certain that the filing includes all in formation required under the Securities Exchange Act of 1934 and th at they have provided all information investors require for an informed invest ment decision. Since the company and its management are in possession of all facts re lating to a company’s disclosure, they are responsible for the accuracy and adequacy of the disclosures they have made.
In connection with responding to our co mments, please provide, in your letter, a statement from the company acknowledging that:
• the company is responsible for the adequacy and accuracy of the disclosure in the filings; • staff comments or changes to disclosure in response to staff comments do not foreclose the Commission from taking any action with respect to the filing; and • the company may not assert staff comme nts as a defense in any proceeding initiated by the Commission or any person under the federal secu rities laws of the United States.
In addition, please be advi sed that the Division of En forcement has access to all information you provide to the staff of the Divi sion of Corporation Fi nance in our review of your filing or in response to our comments on your filing.
You may contact Frank Wyman, St aff Accountant, at 202-551-3660 or Don Abbott, Senior Staff Accountant, at 202- 551-3608, if you have questions regarding the comments. In this regard, do not hes itate to contact me, at (202) 551-3679.
S i n c e r e l y ,
J i m B . R o s e n b e r g Senior Assistant Chief Accountant
Show Raw Text
Mail Stop 6010
Via Facsimile and U.S. Mail
September 25, 2006
Mr. C. Robert Henrikson
Chairman, President and Chief Executive Officer
MetLife, Inc.
200 Park Avenue
New York, New York 10166-0188
Re: MetLife, Inc.
Form 10-K for fiscal year ended December 31, 2005
File No. 001-15787
Dear Mr. Henrikson:
We have limited our review of your filing to those issues we have addressed in
our comments. In our comments, we ask you to provide us with information so we may
better understand your disclosure. After re viewing this information, we may raise
additional comments.
Please understand that the purpose of our re view process is to assist you in your
compliance with the applicable disclosure requirements and to enhance the overall
disclosure in your filing. We look forward to working with you in these respects. We
welcome any questions you may have about our comments or any other aspect of our
review. Feel free to call us at the telephone numbers listed at the end of this letter.
Form 10-K for fiscal year ended December 31, 2005
Managements’ Discussion and Analysis of Fi nancial Condition and Results of Operations
Summary of Critical Acc ounting Estimates, page 60
1. We believe your disclosure could be impr oved to better explain the judgments and
uncertainties in applying critical ac counting estimates for DAC and VOBA and
the likelihood that materially different amounts would be reported under different conditions or using different assumptions. Please provide us in disclosure-type
format the financial statement impact that reasonably likely changes in key
assumptions underlying the December 31, 2005 estimates may have on financial
position and results of operations. Refer to Section V of Financial Reporting
Release No. 72.
Mr. C. Robert Henrikson
MetLife, Inc.
September 25, 2006 Page 2
Discussion of Results, page 67
2. Given the apparent significance of “interes t spreads” to your operating results for
the institutional and individual segments, we believe that your disclosure could be
improved. Please provide to us, in disclosure-type format, the following information for each of these segments.
• Quantify the dollar impact on operating results that corresponds to the
percentage “interest spread” for each period presented.
• Describe how you compute “yield on invested assets” and quantify the
resulting dollar amount used to determine the “interest spread” for each period presented.
• Describe how you compute “interest rate used to credit on certain
liabilities” and quantify the resulting dollar amount used to determine the “interest spread” for each period presented.
• Describe the factors that you considered in determining the expected range
for “interest spreads” for each peri od presented. Explain why you used
different “interest spreads” for 2004 in your comparisons of Institutional segment operating results for 2005/2004 and 2004/2003.
• Explain more specifically the factor s underlying the change in “interest
spread” and the variance between the expected and actual spreads for each
period presented. We note that for n on-medical health & other business,
the actual spread was 3.38% for 2005 and 3.06% for 2004 as compared to the expected spread range of 1.3 to 1.6% at December 31, 2005 and 1.3 to 1.5% at December 31, 2004.
Liquidity and Capital Resources
Contractual Obligations, page 94
3. You state that “lia bilities for future policy be nefits of $82.4 billion and
policyholder account balances of $113.4 b illion both at December 31, 2005 have
been excluded from the table” because in general the insurable event (e.g. death
or disability) or triggering event has not yet occurred. However, you also make
extensive use of asset/lia bility matching processes, whereby you “regularly
reevaluate estimates used in determin ing the approximate amounts and timing of
payments to or on behalf of policy hol ders for insurance liabilities.” These
capabilities appear to indicate that you regularly estimate the information
described in Item 303 (a) (5) of Regulati on S-K. Please provide us a revised table
including estimates for the amount and timi ng of payments related to the excluded
amounts or explain more specifically for each product line why you are unable to provide this information in the ta ble of contractual obligations.
* * * *
Mr. C. Robert Henrikson
MetLife, Inc.
September 25, 2006 Page 3
Please respond to these comments within 10 business days or tell us when you
will provide us with a response. Your letter should key your responses to our comments.
Detailed letters greatly facil itate our review. Please file your letter on EDGAR under the
form type label CORRESP.
We urge all persons who are responsible for the accuracy and adequacy of the
disclosure in the filing to be certain that the filing includes all in formation required under
the Securities Exchange Act of 1934 and th at they have provided all information
investors require for an informed invest ment decision. Since the company and its
management are in possession of all facts re lating to a company’s disclosure, they are
responsible for the accuracy and adequacy of the disclosures they have made.
In connection with responding to our co mments, please provide, in your letter, a
statement from the company acknowledging that:
• the company is responsible for the adequacy and accuracy of the disclosure in the
filings;
• staff comments or changes to disclosure in response to staff comments do not
foreclose the Commission from taking any action with respect to the filing; and
• the company may not assert staff comme nts as a defense in any proceeding
initiated by the Commission or any person under the federal secu rities laws of the
United States.
In addition, please be advi sed that the Division of En forcement has access to all
information you provide to the staff of the Divi sion of Corporation Fi nance in our review
of your filing or in response to our comments on your filing.
You may contact Frank Wyman, St aff Accountant, at 202-551-3660 or Don
Abbott, Senior Staff Accountant, at 202- 551-3608, if you have questions regarding the
comments. In this regard, do not hes itate to contact me, at (202) 551-3679.
S i n c e r e l y ,
J i m B . R o s e n b e r g
Senior Assistant Chief Accountant