Correspondence 0001527469-24-000002 from 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: Jan. 5, 2024 · CIK: 0001527469 · Accession: 0001527469-24-000002
AI Filing Summary & Sentiment
File numbers found in text: 001-37963
Referenced dates: December 15, 2023, September 18, 2023
Letter
Via EDGAR Division of Corporation Finance Re: Athene Holding Ltd Form 10-K for the Fiscal Year Ended December 31, 2022 Form 8-K dated August 7, 2023 File No. 001-37963
Dear Mr. Henderson and Ms. Lubit:
On behalf of Athene Holding Ltd. (the “Company”), set forth below are responses to the additional comments from the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”) received in the Commission’s letter dated December 15, 2023 (the “Third Comment Letter”), relating to the Company’s filings on Form 10-K and Form 8-K and the responses the Company provided on September 29, 2023 and November 13, 2023 in reference to comments received from the Staff in letters dated September 18, 2023 and October 30, 2023. To facilitate the Staff’s review, we have reproduced the text of the Staff’s comments from the Third Comment Letter in bold italics below.
Form 8-K dated August 7, 2023
Exhibit 99.1
Selected Income Statement Data, page 4
•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.
Response:
The Company acknowledges the Staff’s comment and will remove the alternative investment income normalizing adjustment and the related non-GAAP measures in future 8-K filings.
Athene Holding Ltd.
7700 Mills Civic Pkwy, West Des Moines, Iowa 50266
Tel: 1.888.266.8489 Fax: 1.866.709.3922
Athene.com
Mr. Michael Henderson and Ms. Cara Lubit
U.S. Securities and Exchange Commission
January 5, 2024
Page 2
Should any member of the Staff have any questions or comments concerning the responses submitted herein, please do not hesitate to contact me at (515) 342-3860.
Sincerely,
/s/ Martin P. Klein
Show Raw Text
CORRESP 1 filename1.htm Document January 5, 2024 Via EDGAR Mr. Michael Henderson Ms. Cara Lubit Division of Corporation Finance U.S. Securities and Exchange Commission 100 F Street, N.E. Washington, D.C. 20549-3628 Re: Athene Holding Ltd Form 10-K for the Fiscal Year Ended December 31, 2022 Form 8-K dated August 7, 2023 File No. 001-37963 Dear Mr. Henderson and Ms. Lubit: On behalf of Athene Holding Ltd. (the “Company”), set forth below are responses to the additional comments from the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”) received in the Commission’s letter dated December 15, 2023 (the “Third Comment Letter”), relating to the Company’s filings on Form 10-K and Form 8-K and the responses the Company provided on September 29, 2023 and November 13, 2023 in reference to comments received from the Staff in letters dated September 18, 2023 and October 30, 2023. To facilitate the Staff’s review, we have reproduced the text of the Staff’s comments from the Third Comment Letter in bold italics below. Form 8-K dated August 7, 2023 Exhibit 99.1 Selected Income Statement Data, page 4 •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. Response: The Company acknowledges the Staff’s comment and will remove the alternative investment income normalizing adjustment and the related non-GAAP measures in future 8-K filings. Athene Holding Ltd. 7700 Mills Civic Pkwy, West Des Moines, Iowa 50266 Tel: 1.888.266.8489 Fax: 1.866.709.3922 Athene.com Mr. Michael Henderson and Ms. Cara Lubit U.S. Securities and Exchange Commission January 5, 2024 Page 2 Should any member of the Staff have any questions or comments concerning the responses submitted herein, please do not hesitate to contact me at (515) 342-3860. Sincerely, /s/ Martin P. Klein Martin P. Klein Executive Vice President and Chief Financial Officer, Athene Holding Ltd.