SEC Company Response from METLIFE (MET) — Dec 19, 2017
METLIFE INC
Date: Dec. 19, 2017 · CIK: 0001099219 · Accession: 0001193125-17-373675
AI Filing Summary & Sentiment
File numbers found in text: 001-15787
Referenced dates: December 5, 2017
Letter
Office of Healthcare & Insurance Division of Corporation Finance United States Securities and Exchange Commission Re: MetLife, Inc. Form 10-Q for the Quarterly Period Ended September 30, 2017 Filed November 6, 2017 File No. 001-15787
Dear Ladies and Gentlemen:
This letter sets forth the response of MetLife, Inc. (the “Company”) to the comments contained in your letter dated December 5, 2017 regarding the Company’s Form 10-Q referenced above.
In response to your comments, we have reproduced your comments below in boldface, italic type and set forth our response immediately below each comment.
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).
Management’s Response:
We confirm that, to the extent we include such non-GAAP measures in our filings beginning with 2017 fourth quarter and full-year disclosures, we will revise the titles of those measures to provide an appropriate description of each measure that complies with Item 10(e).
Office of Healthcare & Insurance
Securities and Exchange Commission
December 19, 2017
Page
If we may be of assistance in answering any questions that may arise in connection with the staff’s review of our response letter, please call me at 212-578-5353. For your convenience, we are filing this letter on EDGAR under the form type label CORRESP.
Sincerely,
/s/ William O’Donnell
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CORRESP 1 filename1.htm CORRESP William O’Donnell Executive Vice President and Chief Accounting Officer bodonnell1@metlife.com December 19, 2017 Office of Healthcare & Insurance Division of Corporation Finance United States Securities and Exchange Commission 100 F Street, N.E. Washington, D.C. 20549 Re: MetLife, Inc. Form 10-Q for the Quarterly Period Ended September 30, 2017 Filed November 6, 2017 File No. 001-15787 Dear Ladies and Gentlemen: This letter sets forth the response of MetLife, Inc. (the “Company”) to the comments contained in your letter dated December 5, 2017 regarding the Company’s Form 10-Q referenced above. In response to your comments, we have reproduced your comments below in boldface, italic type and set forth our response immediately below each comment. 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). Management’s Response: We confirm that, to the extent we include such non-GAAP measures in our filings beginning with 2017 fourth quarter and full-year disclosures, we will revise the titles of those measures to provide an appropriate description of each measure that complies with Item 10(e). Office of Healthcare & Insurance Securities and Exchange Commission December 19, 2017 Page 2 If we may be of assistance in answering any questions that may arise in connection with the staff’s review of our response letter, please call me at 212-578-5353. For your convenience, we are filing this letter on EDGAR under the form type label CORRESP. Sincerely, /s/ William O’Donnell William O’Donnell cc: Steven A. Kandarian John C. R. Hele Stephen W. Gauster