SEC Comment Letter for METLIFE (MET) — Jul 24, 2012
METLIFE INC
Date: July 24, 2012 · CIK: 0001099219 · Accession: 0000000000-12-039304
AI Filing Summary & Sentiment
File numbers found in text: 001-15787
Letter
July 24, 2012 Via E -mail Peter M. Carlson Executive Vice President and Chief Accounting Officer MetLife , Inc. 1300 Hall Boulevard Bloomfield, Connecticut 06002
Re: MetLife, Inc. Form 10-K for the Fiscal Year Ended December 31, 2011 Filed February 28, 2012 Form 10-Q for the Quarterly Period Ended March 31, 2012 Filed May 8, 2012 File No. 001-15787
Dear Mr. Carlson :
We have reviewed your June 25 , 2012 response to our June 7 , 2012 letter and have the following comments.
Please respond to this letter within 10 business days by amending your filing , 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 or do not believe an amendment is appropriate, please tell us why in your response. Please furnish us a letter on EDGAR under the form type label CORRESP that key s your responses to our comments.
After reviewing any amendment s to your filing s and the information you provide in response to th ese comment s, we may have additional comments.
Form 10 -K for the Fiscal Year Ended December 31, 2011 Item 8. Financial Statements and Supplementary Data Notes to the Consolidated Financial Statements 18. Equity Statutory Equity and Income, page 409
1. With respect to your statutory disclosures, please amend your filing to address the following:
Peter M. Carlson MetLife , Inc. July 24, 2012 Page 2
The disclosure in this Note is required by ASC 944 -505-50 and Article 7 Rule 7.03(a)(23)(c) of Regulation S -X and is thus required to be audited. Please revise your filing to include the information on an audited basis. The reason for the use of “approximate” in you r statements: “ Represents approximate statutory net income (loss)(unaudited).” and “Represents approxi mate statutory capital and surplus (unaudited) .”
Form 10 -Q for the Quarterly Period Ended March 31, 2012 Management’s Discussion and Analysis, page 128
2. Since your proposed disclosure does not include amounts for March 31, 2012 , it does not more fully explain the $2 billion of net derivative losses as requested. Please provide us revised proposed disclosure to include quantification .
Please contact James Peklenk, Staff Accountant, at (202) 551 -3661 or Lisa Vanjoske, Assistant Chief Accountant, at (202) 551 -3614 if you have any questions regarding the comments . In this regard, do not hesitate to contact me at (202) 551 -3679.
Sincerely,
/s/ Jim B. Rosenberg
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July 24, 2012 Via E -mail Peter M. Carlson Executive Vice President and Chief Accounting Officer MetLife , Inc. 1300 Hall Boulevard Bloomfield, Connecticut 06002 Re: MetLife, Inc. Form 10-K for the Fiscal Year Ended December 31, 2011 Filed February 28, 2012 Form 10-Q for the Quarterly Period Ended March 31, 2012 Filed May 8, 2012 File No. 001-15787 Dear Mr. Carlson : We have reviewed your June 25 , 2012 response to our June 7 , 2012 letter and have the following comments. Please respond to this letter within 10 business days by amending your filing , 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 or do not believe an amendment is appropriate, please tell us why in your response. Please furnish us a letter on EDGAR under the form type label CORRESP that key s your responses to our comments. After reviewing any amendment s to your filing s and the information you provide in response to th ese comment s, we may have additional comments. Form 10 -K for the Fiscal Year Ended December 31, 2011 Item 8. Financial Statements and Supplementary Data Notes to the Consolidated Financial Statements 18. Equity Statutory Equity and Income, page 409 1. With respect to your statutory disclosures, please amend your filing to address the following: Peter M. Carlson MetLife , Inc. July 24, 2012 Page 2 The disclosure in this Note is required by ASC 944 -505-50 and Article 7 Rule 7.03(a)(23)(c) of Regulation S -X and is thus required to be audited. Please revise your filing to include the information on an audited basis. The reason for the use of “approximate” in you r statements: “ Represents approximate statutory net income (loss)(unaudited).” and “Represents approxi mate statutory capital and surplus (unaudited) .” Form 10 -Q for the Quarterly Period Ended March 31, 2012 Management’s Discussion and Analysis, page 128 2. Since your proposed disclosure does not include amounts for March 31, 2012 , it does not more fully explain the $2 billion of net derivative losses as requested. Please provide us revised proposed disclosure to include quantification . Please contact James Peklenk, Staff Accountant, at (202) 551 -3661 or Lisa Vanjoske, Assistant Chief Accountant, at (202) 551 -3614 if you have any 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