SecProbe.io

December 5, 2017
Michael S. Smith
Executive Vice President and Chief Financial Officer
Voya Financial, Inc.
230 Park Avenue
New York, NY 10169
Re:Voya Financial, Inc.
Form 10-Q for the quarterly period ended September 30, 2017
Filed November 1, 2017
File No. 001-35897
Dear Mr. Smith:
            We have limited our review of your filing to those issues we have addressed in our
comments.  In some of our comments, we may ask you to provide us with information so we
may better understand your disclosure.
            Please respond to these 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 our
comments apply to your facts and circumstances, please tell us why in your response.
            After reviewing your response to these comments, we may have additional comments.
Form 10-Q for the quarterly period ended September 30, 2017
Management’s Discussion and Analysis of Financial Condition and Results of Operations
Operating Measures, page 106
1.Please confirm to us that in future filings you will clearly indicate that "total operating
earnings before income taxes" is a non-GAAP measure. Further, "total operating earnings
before income taxes" appears to be a title that is the same as, or confusingly similar to,
that used for a GAAP financial measure and precluded by Item 10(e)(ii)(E) of Regulation
S-K. As such, please also confirm to us that you will revise the title of this measure in
future filings to provide an appropriate description of it that complies with Item 10(e).
2.Please confirm to us that in future filings you will begin your reconciliations with the
GAAP amounts rather than the non-GAAP amounts. See Question 102.10 of the updated

 FirstName LastNameMichael S.  Smith
 Comapany NameVoya Financial, Inc.
 June 16, 2017 Page 2
 FirstName LastName
Michael S.  Smith
Voya Financial, Inc.
December 5, 2017
Page 2
Non-GAAP Compliance and Disclosure Interpretations issued on May 17, 2016.
3.Please confirm to us that in future filings you will remove the measure titled "total
operating earnings before income taxes" from Note 15 Segments on page 84 pursuant to
Item 10(e)(1)(ii)(C) of Regulation S-K.
            In closing, we remind you that the company and its management are responsible for the
accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or
absence of action by the staff.
            You may contact Vanessa Robertson at 202-551-3649 or Kevin Vaughn at 202-551-3494
with any questions.
Division of Corporation Finance
Office of Healthcare & Insurance