SEC Company Response from PRINCIPAL FINANCIAL GROUP (PFG) — Aug 16, 2010
PRINCIPAL FINANCIAL GROUP INC
Date: Aug. 16, 2010 · CIK: 0001126328 · Accession: 0000898745-10-000418
AI Filing Summary & Sentiment
File numbers found in text: 001-16725
Referenced dates: June 29, 2010
Letter
Securities and Exchange Commission Division of Corporation Finance Attention: Mr. Jim Rosenberg, Re: Principal Financial Group, Inc. Form 10-K for the Fiscal Year Ended December 31, 2009 Form 10-Q for the Quarterly Period Ended March 31, 2010 File No. 001-16725
Dear Mr. Rosenberg:
This letter supplements the response of Principal Financial Group, Inc. to the comments of the
Division of Corporation Finance of the Securities and Exchange Commission contained in your
letter dated June 29, 2010, concerning the company’s annual report on Form 10-K and quarterly
report on Form 10-Q, both referenced above. Our response was dated and filed via EDGAR on
August 13, 2010, and inadvertently failed to include the following language.
We acknowledge that we are responsible for the adequacy and accuracy of the disclosure
contained in our periodic reports filed pursuant to the Securities Exchange Act of 1934, and that
your comments or our changes to disclosure in response to your comments do not foreclose the
Commission from taking any action with respect to our reports. Further, we acknowledge that
we may not assert your comments as a defense in any proceeding initiated by the Commission or
any person under the federal securities laws of the United States.
Sincerely,
/s/ Terrance J. Lillis
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supplementltrto081310respons.htm - Generated by SEC Publisher for SEC Filing
August 16, 2010
By EDGAR
Securities and Exchange Commission
Division of Corporation Finance
100 F Street, N.E.
Washington D.C. 20549
Attention:
Mr. Jim Rosenberg,
Senior Assistant Chief Accountant
Re:
Principal Financial Group, Inc.
Form 10-K for the Fiscal Year Ended December 31, 2009
Form 10-Q for the Quarterly Period Ended March 31, 2010
File No. 001-16725
Dear Mr. Rosenberg:
This letter supplements the response of Principal Financial Group, Inc. to the comments of the
Division of Corporation Finance of the Securities and Exchange Commission contained in your
letter dated June 29, 2010, concerning the company’s annual report on Form 10-K and quarterly
report on Form 10-Q, both referenced above. Our response was dated and filed via EDGAR on
August 13, 2010, and inadvertently failed to include the following language.
We acknowledge that we are responsible for the adequacy and accuracy of the disclosure
contained in our periodic reports filed pursuant to the Securities Exchange Act of 1934, and that
your comments or our changes to disclosure in response to your comments do not foreclose the
Commission from taking any action with respect to our reports. Further, we acknowledge that
we may not assert your comments as a defense in any proceeding initiated by the Commission or
any person under the federal securities laws of the United States.
Sincerely,
/s/ Terrance J. Lillis
Terrance J. Lillis
Senior Vice President and
Chief Financial Officer
(515) 247-4885
cc:
Vanessa Robertson (Securities and Exchange Commission)
Mary Mast (Securities and Exchange Commission)