SEC Comment Letter for METLIFE (MET) — Dec 5, 2017
METLIFE INC
Date: Dec. 5, 2017 · CIK: 0001099219 · Accession: 0000000000-17-042540
AI Filing Summary & Sentiment
File numbers found in text: 001-15787
Letter
December 5, 2017 John C. R. Hele Executive Vice President and Chief Financial Officer MetLife, Inc. 200 Park Avenue New York, NY 10166-0188 Re:MetLife, Inc. Form 10-Q for the Quarterly Period Ended September 30, 2017 Filed November 6, 2017 File No. 001-15787 Dear Mr. Hele: We have limited our review of your filing to the issue we have addressed in our comment. In our comment, we ask you to provide us with information so we may better understand your disclosure. Please respond to this comment 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 the comment applies to your facts and circumstances, please tell us why in your response. After reviewing your response to this comment, we may have additional comments. Form 10-Q for the Quarterly Period Ended September 30, 2017 Management's Discussion and Analysis of Financial Condition and Results of Operations Non-GAAP and Other Financial Disclosures, page 183 1."Operating revenues", "operating expenses" and "operating earnings" that you identify as non-GAAP measures appear to be titles that are the same as, or confusingly similar to, those used for GAAP financial measures and precluded by Item 10(e)(ii)(E) of Regulation S-K. As such, please confirm to us that you will revise the titles of these measures in future filings to provide an appropriate description of each measure that complies with Item 10(e). 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
FirstName LastNameJohn C. R. Hele Comapany NameMetLife, Inc. June 16, 2017 Page 2 FirstName LastName John C. R. Hele MetLife, Inc. December 5, 2017 Page 2 absence of action by the staff. You may contact Vanessa Robertson at 202-551-3649 or Kevin Vaughn at 202-551-3494 with any questions. Division of Corporation Finance Office of Healthcare & Insurance
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December 5, 2017
John C. R. Hele
Executive Vice President and Chief Financial Officer
MetLife, Inc.
200 Park Avenue
New York, NY 10166-0188
Re:MetLife, Inc.
Form 10-Q for the Quarterly Period Ended September 30, 2017
Filed November 6, 2017
File No. 001-15787
Dear Mr. Hele:
We have limited our review of your filing to the issue we have addressed in our
comment. In our comment, we ask you to provide us with information so we may better
understand your disclosure.
Please respond to this comment 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 the
comment applies to your facts and circumstances, please tell us why in your response.
After reviewing your response to this comment, we may have additional comments.
Form 10-Q for the Quarterly Period Ended September 30, 2017
Management's Discussion and Analysis of Financial Condition and Results of Operations
Non-GAAP and Other Financial Disclosures, page 183
1."Operating revenues", "operating expenses" and "operating earnings" that you identify
as non-GAAP measures appear to be titles that are the same as, or confusingly similar to,
those used for GAAP financial measures and precluded by Item 10(e)(ii)(E) of
Regulation S-K. As such, please confirm to us that you will revise the titles of these
measures in future filings to provide an appropriate description of each measure that
complies with Item 10(e).
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
FirstName LastNameJohn C. R. Hele
Comapany NameMetLife, Inc.
June 16, 2017 Page 2
FirstName LastName
John C. R. Hele
MetLife, Inc.
December 5, 2017
Page 2
absence of action by the staff.
You may contact Vanessa Robertson at 202-551-3649 or Kevin Vaughn at 202-551-3494
with any questions.
Division of Corporation Finance
Office of Healthcare & Insurance