SEC Comment Letter for METLIFE (MET) — Jul 11, 2011
METLIFE INC
Date: July 11, 2011 · CIK: 0001099219 · Accession: 0000000000-11-041872
AI Filing Summary & Sentiment
File numbers found in text: 001-15787
Letter
July 11, 2011 Via E-mail C. Robert Henrikson Chairman of the Board, President and Chief Executive Officer MetLife, Inc. 200 Park Avenue New York, N.Y. 10166-0188 Re: MetLife, Inc. Form 10-K for the Fiscal Year Ended December 31, 2010 Filed February 25, 2011 File No. 001-15787
Dear Mr. Henrikson:
We have reviewed your June 13, 2011 response to our May 27, 2011 letter and have the following comments.
Please respond to this letter within te n business days by providing the requested information or by advising us when you will provide the requested response. If you do not believe a comment applies to your facts and circ umstances, please tell us why in your response. Please furnish us a letter on EDGAR under the fo rm type label CORRESP that keys your responses to our comments.
After reviewing the information you provide in response to the comments, we may have additional comments.
Item 8. Financial Statements and Supplementary Data
Notes to the Consolidated Financial Statements 1. Business, Basis of Presentation and Summary of Significan t Accounting Policies
Summary of Significant Accounting Polic ies and Critical Accounting Estimates Investments Real Estate Joint Ventures and Other Li mited Partnership Interests, page F-17
1. Please refer to your response to prior comme nt six. Please provide us an analysis supporting your belief that a limited partners hip interest does not meet the definition of an equity security and thus, ASC 944-325-30- 1 is not applicable. Refer to ASC 320-10- 20.
C. Robert Henrikson Metlife, Inc. July 11, 2011 Page 2
2. Acquisitions and Dispositions
2010 Acquisition of ALICO Recording of Assets Acquired and Liabilities Assumed Identified Intangibles, page F-44
2. Refer to your response to prior comment seven. Please confirm to us that you will revise your disclosure beginning with the Form 10-Q for the Quarterly Period Ended June 30,2011 to include your summary of the major blocks of business for which negative VOBA was recorded and the reasons why the fair value of the liabilities associated with these blocks exceeded the ini tial policy reserves assumed.
3. Refer to your response to prior comment seven. Given that your Form 10-K will not be filed until early 2012, please confirm to us th at you will revise your disclosure beginning with your Form 10-Q for the Quarterly Period Ended June 30, 2011 to include the weighted average amortization period for your negative VOBA and the estimated amortization for each of the next five years.
You may contact Staci Shannon, Staff Account ant, at (202) 551- 3374 or Mary Mast, Review Accountant, at (202) 551-3613 if you have questions regarding the comments. 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
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July 11, 2011 Via E-mail C. Robert Henrikson Chairman of the Board, President and Chief Executive Officer MetLife, Inc. 200 Park Avenue New York, N.Y. 10166-0188 Re: MetLife, Inc. Form 10-K for the Fiscal Year Ended December 31, 2010 Filed February 25, 2011 File No. 001-15787 Dear Mr. Henrikson: We have reviewed your June 13, 2011 response to our May 27, 2011 letter and have the following comments. Please respond to this letter within te n business days by providing the requested information or by advising us when you will provide the requested response. If you do not believe a comment applies to your facts and circ umstances, please tell us why in your response. Please furnish us a letter on EDGAR under the fo rm type label CORRESP that keys your responses to our comments. After reviewing the information you provide in response to the comments, we may have additional comments. Item 8. Financial Statements and Supplementary Data Notes to the Consolidated Financial Statements 1. Business, Basis of Presentation and Summary of Significan t Accounting Policies Summary of Significant Accounting Polic ies and Critical Accounting Estimates Investments Real Estate Joint Ventures and Other Li mited Partnership Interests, page F-17 1. Please refer to your response to prior comme nt six. Please provide us an analysis supporting your belief that a limited partners hip interest does not meet the definition of an equity security and thus, ASC 944-325-30- 1 is not applicable. Refer to ASC 320-10- 20. C. Robert Henrikson Metlife, Inc. July 11, 2011 Page 2 2. Acquisitions and Dispositions 2010 Acquisition of ALICO Recording of Assets Acquired and Liabilities Assumed Identified Intangibles, page F-44 2. Refer to your response to prior comment seven. Please confirm to us that you will revise your disclosure beginning with the Form 10-Q for the Quarterly Period Ended June 30,2011 to include your summary of the major blocks of business for which negative VOBA was recorded and the reasons why the fair value of the liabilities associated with these blocks exceeded the ini tial policy reserves assumed. 3. Refer to your response to prior comment seven. Given that your Form 10-K will not be filed until early 2012, please confirm to us th at you will revise your disclosure beginning with your Form 10-Q for the Quarterly Period Ended June 30, 2011 to include the weighted average amortization period for your negative VOBA and the estimated amortization for each of the next five years. You may contact Staci Shannon, Staff Account ant, at (202) 551- 3374 or Mary Mast, Review Accountant, at (202) 551-3613 if you have questions regarding the comments. 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