SEC Comment Letter 0000000000-23-013744 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: Dec. 15, 2023 · CIK: 0001527469 · Accession: 0000000000-23-013744
AI Filing Summary & Sentiment
File numbers found in text: 001-37963
Referenced dates: September 18, 2023
Letter
United States securities and exchange commission logo December 15, 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 November 13, 2023 File No. 001-37963 Dear Martin P. Klein: We have reviewed your November 13, 2023 response to our comment letter and have the following comment. 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 the 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 October 30, 2023 letter. Form 8-K dated August 7, 2023 Exhibit 99.1 Selected Income Statement Data, page 4 1.We note your response to prior comments 1 and 2, as well as your response to comment 3 in our letter dated September 18, 2023. The adjustment to normalize alternative investment income to an 11% long-term return represents an individually tailored accounting method that has the effect of changing the recognition and measurement principles required to be applied in accordance with GAAP. Therefore, please remove the presentation of this adjustment and related measures from your future filings. Refer to Question 100.04 of the Division of Corporation Finance’s Compliance & Disclosure Interpretations on Non-GAAP Financial Measures and Rule 100(b) of Regulation G.
FirstName LastNameMartin P. Klein Comapany NameAthene Holding Ltd December 15, 2023 Page 2 FirstName LastName Martin P. Klein Athene Holding Ltd December 15, 2023 Page 2 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
December 15, 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 November 13, 2023
File No. 001-37963
Dear Martin P. Klein:
We have reviewed your November 13, 2023 response to our comment letter and have the
following comment.
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 the
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 October 30, 2023
letter.
Form 8-K dated August 7, 2023
Exhibit 99.1
Selected Income Statement Data, page 4
1.We note your response to prior comments 1 and 2, as well as your response to comment 3
in our letter dated September 18, 2023. The adjustment to normalize alternative
investment income to an 11% long-term return represents an individually tailored
accounting method that has the effect of changing the recognition and measurement
principles required to be applied in accordance with GAAP. Therefore, please remove the
presentation of this adjustment and related measures from your future filings. Refer to
Question 100.04 of the Division of Corporation Finance’s Compliance & Disclosure
Interpretations on Non-GAAP Financial Measures and Rule 100(b) of Regulation G.
FirstName LastNameMartin P. Klein
Comapany NameAthene Holding Ltd
December 15, 2023 Page 2
FirstName LastName
Martin P. Klein
Athene Holding Ltd
December 15, 2023
Page 2
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