SEC Comment Letter 0000000000-23-011876 to Athene Holding Ltd. (ATHS, ATH-PA, ATH-PB, ATH-PC, ATH-PD, ATH-PE) (CIK 0001527469) (ATHS)
Athene Holding Ltd. (ATHS, ATH-PA, ATH-PB, ATH-PC, ATH-PD, ATH-PE) (CIK 0001527469)
Date: Oct. 30, 2023 · CIK: 0001527469 · Accession: 0000000000-23-011876
AI Filing Summary & Sentiment
File numbers found in text: 001-37963
Letter
United States securities and exchange commission logo October 30, 2023 Martin P. Klein Chief Financial Officer Athene Holding Ltd Second Floor, Washington House 16 Church Street Hamilton, HM 11, Bermuda Re:Athene Holding Ltd Form 10-K for the Fiscal Year Ended December 31, 2022 Response dated September 29, 2023 File No. 001-37963 Dear Martin P. Klein: We have reviewed your September 29, 2023 response to our comment letter and have the following comments. Please respond to this letter 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 applies to your facts and circumstances, please tell us why in your response. After reviewing your response to this letter, we may have additional comments. Unless we note otherwise, any references to prior comments are to comments in our September 18, 2023 letter. Form 8-K dated August 7, 2023 Exhibit 99.1 Selected Income Statement Data, page 4 1.We note your response to comment three, in which you state that your alternative investment portfolio has returned approximately 12%, on average, over the past ten years and that you have based your expectation of returns on this and adjusted down to 11% for conservatism. Please address the items below. •Explain the reasons and factors you considered in determining that ten years is an appropriate lookback period and how your average and estimated rates of return would be affected by a different (longer or shorter) period. •Tell us how your long-term expectation of returns for this asset class has compared to actual returns and how you determined that the prior ten years would be reflective of
FirstName LastNameMartin P. Klein Comapany NameAthene Holding Ltd October 30, 2023 Page 2 FirstName LastName Martin P. Klein Athene Holding Ltd October 30, 2023 Page 2 forward-looking long-term performance expectations. •Explain how you determined that 11% is an appropriate adjustment level for conservatism, as well as whether you adjust this level and, if so, under what circumstances. 2.In addition to the above, please provide us with a more fulsome explanation of your rationale and considerations in determining that this normalization adjustment is not individually tailored accounting. For example, your response states that your adjustment does not change the recognition and measurement principles; however, it is still unclear to us how you reached this conclusion, given that actual recognition and measurement of alternative investment income, as reflected in your financial statements under U.S. GAAP, are not fixed at 11%. Please contact Michael Henderson at 202-551-3364 or Cara Lubit at 202-551-5909 if you have questions regarding comments on the financial statements and related matters. Sincerely, Division of Corporation Finance Office of Finance
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United States securities and exchange commission logo
October 30, 2023
Martin P. Klein
Chief Financial Officer
Athene Holding Ltd
Second Floor, Washington House
16 Church Street
Hamilton, HM 11, Bermuda
Re:Athene Holding Ltd
Form 10-K for the Fiscal Year Ended December 31, 2022
Response dated September 29, 2023
File No. 001-37963
Dear Martin P. Klein:
We have reviewed your September 29, 2023 response to our comment letter and have the
following comments.
Please respond to this letter 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 applies to your facts and circumstances, please tell us why in your response.
After reviewing your response to this letter, we may have additional comments. Unless
we note otherwise, any references to prior comments are to comments in our September 18,
2023 letter.
Form 8-K dated August 7, 2023
Exhibit 99.1
Selected Income Statement Data, page 4
1.We note your response to comment three, in which you state that your alternative
investment portfolio has returned approximately 12%, on average, over the past ten years
and that you have based your expectation of returns on this and adjusted down to 11% for
conservatism. Please address the items below.
•Explain the reasons and factors you considered in determining that ten years is an
appropriate lookback period and how your average and estimated rates of return
would be affected by a different (longer or shorter) period.
•Tell us how your long-term expectation of returns for this asset class has compared to
actual returns and how you determined that the prior ten years would be reflective of
FirstName LastNameMartin P. Klein
Comapany NameAthene Holding Ltd
October 30, 2023 Page 2
FirstName LastName
Martin P. Klein
Athene Holding Ltd
October 30, 2023
Page 2
forward-looking long-term performance expectations.
•Explain how you determined that 11% is an appropriate adjustment level for
conservatism, as well as whether you adjust this level and, if so, under what
circumstances.
2.In addition to the above, please provide us with a more fulsome explanation of your
rationale and considerations in determining that this normalization adjustment is not
individually tailored accounting. For example, your response states that your adjustment
does not change the recognition and measurement principles; however, it is still unclear to
us how you reached this conclusion, given that actual recognition and measurement of
alternative investment income, as reflected in your financial statements under U.S. GAAP,
are not fixed at 11%.
Please contact Michael Henderson at 202-551-3364 or Cara Lubit at 202-551-5909 if you
have questions regarding comments on the financial statements and related matters.
Sincerely,
Division of Corporation Finance
Office of Finance