SEC Comment Letter for PRINCIPAL FINANCIAL GROUP (PFG) — Mar 16, 2016
PRINCIPAL FINANCIAL GROUP INC
Date: March 16, 2016 · CIK: 0001126328 · Accession: 0000000000-16-068527
AI Filing Summary & Sentiment
File numbers found in text: 001-16725
Letter
Mail Stop 4720 March 15, 201 6 Via E -mail Mr. Terrance J. Lillis Chief Financial Officer Principal Financial Group Inc . 711 High Street Des Moines, Iowa 50392
Re: Principal Financial Group Inc . Form 10 -K for the Year Ended December 31, 201 5 Filed February 10, 2016 File No. 001-16725
Dear Mr. Lillis :
We have limited our review of your filing to the financial statements and related disclosures and have the following comment s. In our commen ts, we ask you to provide us with information so we may better understand your disclosure.
Please respond to th ese comments 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 a comment appl ies to your facts and circumstances, please tell us why in your response.
After reviewing your response to these comments , we may have additional comments.
Management’s Discussion and Analysis Results of Operations, p age 44
1. Throughout this section including results of operations by segment in cases where you list more than one factor for a change, please provide us an analysis that quantifies each factor .
Financial Statements Note 10. Income Taxes, page 135
2. Please tell us the amount of income before income tax expense for domestic versus foreign operations for each period presented, and tell us why you do not provide this disclosure as required by r ule 4 -08(h) of Regulation S -X.
Mr. Terrance J. Lillis Principal Financial Group Inc. March 15, 2016 Page 2
We urge all persons who are responsible for the accuracy and adequacy of the disclosure in the filing to be certain that the filing include s all information the Securities Exchange Act of 1934 and all applicable Exchange Act rules require. Since the company and its management are in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy and adequacy of the disclosures they have made.
In responding to our comment s, please provide a written statement from the company acknowledging that:
the company is responsible for the adequacy and accuracy of the disclosure in the filing; staff comment s or changes to disclosu re in response to staff comment s do not foreclose the Commission from taking any action with respect to the filing; and the compa ny may not assert the staff comment s as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.
You may contact Lisa Vanjoske , Assistant Chief Accountant, at (202) 551 -3614 or Joel Parker, Accounting Branch Chief, at (202) 551 -3651 if you have any questions regarding the comment s. In this regard, do not hesitate to contact me at (202) 551 -3679 .
Sincerely,
/s/ Jim B. Rosenberg
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Mail Stop 4720 March 15, 201 6 Via E -mail Mr. Terrance J. Lillis Chief Financial Officer Principal Financial Group Inc . 711 High Street Des Moines, Iowa 50392 Re: Principal Financial Group Inc . Form 10 -K for the Year Ended December 31, 201 5 Filed February 10, 2016 File No. 001-16725 Dear Mr. Lillis : We have limited our review of your filing to the financial statements and related disclosures and have the following comment s. In our commen ts, we ask you to provide us with information so we may better understand your disclosure. Please respond to th ese comments 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 a comment appl ies to your facts and circumstances, please tell us why in your response. After reviewing your response to these comments , we may have additional comments. Management’s Discussion and Analysis Results of Operations, p age 44 1. Throughout this section including results of operations by segment in cases where you list more than one factor for a change, please provide us an analysis that quantifies each factor . Financial Statements Note 10. Income Taxes, page 135 2. Please tell us the amount of income before income tax expense for domestic versus foreign operations for each period presented, and tell us why you do not provide this disclosure as required by r ule 4 -08(h) of Regulation S -X. Mr. Terrance J. Lillis Principal Financial Group Inc. March 15, 2016 Page 2 We urge all persons who are responsible for the accuracy and adequacy of the disclosure in the filing to be certain that the filing include s all information the Securities Exchange Act of 1934 and all applicable Exchange Act rules require. Since the company and its management are in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy and adequacy of the disclosures they have made. In responding to our comment s, please provide a written statement from the company acknowledging that: the company is responsible for the adequacy and accuracy of the disclosure in the filing; staff comment s or changes to disclosu re in response to staff comment s do not foreclose the Commission from taking any action with respect to the filing; and the compa ny may not assert the staff comment s as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States. You may contact Lisa Vanjoske , Assistant Chief Accountant, at (202) 551 -3614 or Joel Parker, Accounting Branch Chief, at (202) 551 -3651 if you have any questions regarding the comment s. 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 Office of Healthcare and Insurance