SecProbe.io

April 25, 2025
Conor Murphy
Chief Financial Officer
F&G Annuities & Life, Inc.
801 Grand Avenue
Des Moines, Iowa 50309
Re:F&G Annuities & Life, Inc.
Form 10-K for Fiscal Year Ended December 31, 2024
Form 8-K Filed February 20, 2025
File No. 001-41490
Dear Conor Murphy :
            We have limited our review of your filing to the financial statements and related
disclosures 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.
Form 10-K for Fiscal Year Ended December 31, 2024
Our Strategy, page 11
1.We note your reference to accretive flow reinsurance and flow reinsurance fee income
throughout your filing. Please revise future filings to provide additional information
regarding how flow reinsurance is accretive and explain how you generate fee income
from the flow reinsurance transactions. Please provide us your proposed disclosure.
Non-GAAP Financial Measures, page 87
We note your prominent disclosure and discussion related to the Adjusted Net
Earnings non-GAAP financial measure and the material adjustments on page 99
related to “Recognized gains and losses, net” and “Market related liability
adjustments.” Please revise future filings to more clearly describe why you back out
the impact of the multitude of transactions included in these two adjustments and why
you consider the resulting measure to be useful in understanding your overall results
of operations.  Further, we note you back out only certain recognized gains and losses. 2.

April 25, 2025
Page 2
Compare and contrast the key characteristics of recognized gains and losses left in as
compared to those backed out. Please provide us your proposed disclosure.
3.We note your prominent disclosure and discussion related to AUM, AAUM and yield
on AAUM. Please revise future filings to quantify the components of AUM, in
appropriate detail, disclose the annualized net investment income used in the yield
calculation and discuss any differences between annualized net investment income
used in the yield calculation and US GAAP interest and investment income disclosed
in the income statement. Additionally, please clarify if investments related to the
coinsurance with funds withheld arrangements are included in these measures. Please
provide us your proposed disclosure.
Investment Portfolio, page 99
4.We note your disclosure related to your alternative investments throughout your Form
10-K, quarterly financial supplements and investor presentations and that you
recognized $514 million of investment income from alternative investments in 2024
representing 19% of total interest and investment income. Please revise future filings
to provide a quantitative breakdown of the investments that are considered to be
alternative investments and the related amount of investment income recognized for
each period presented. Please provide us your proposed disclosure.
5.Please revise future filings to disclose the investments that are in the funds withheld
account as of each period end presented.
Investments - Fixed Maturity Securities Available-for-Sale, page 134
6.We note your disclosure that “realized gains and losses on sales of our fixed maturity
securities are determined on the first-in first-out cost basis.” Please tell us why you
use the first-in first out basis to determine the cost basis of sold fixed maturity
securities available-for-sale as compared to the specific identification method. Tell us
the nature of your investments in fixed maturity securities available-for-sale that
results in first-in first-out being appropriate.
Funds Withheld Arrangements, page 142
7.Please revise future filings to disclose your accounting policies related to “Funds
withheld for reinsurance liabilities.” Specifically disclose what items are included in
this line item presented in your Consolidated Balance Sheets and how they are
recognized and measured.
Recognized Gains and (Losses), Net, page 166
8.It appears the “Realized (losses) gains on derivatives and embedded derivatives” line
item in the table on page 166 represents a sub-total for “Derivatives and embedded
derivatives.” Please explain to us why it is labeled as “Realized” when it appears to
include both realized and unrealized amounts. Alternatively, please revise the line
item description, as appropriate, in future filings.
Note D - Derivative Financial Instruments, page 168
We note your disclosure on page 82 that the compound embedded derivatives related 9.

April 25, 2025
Page 3
to arrangements reinsuring indexed annuities products are reported in "Funds withheld
for reinsurance liabilities". Please tell us where these derivatives are presented in the
first table on page 168.  If material, please revise future filings to more clearly present
this information.
Note O - Insurance Subsidiary Financial Information and Regulatory Matters, page 196
10.For each material entity, please revise future filings to disclose the amount of statutory
capital and surplus necessary to satisfy regulatory requirements if significant in
relation to the entity’s statutory capital and surplus. Refer to ASC 944-505-50-1 for
guidance. Please provide us your proposed disclosure.
Form 8-K Filed February 20, 2025
Exhibit 99.3 F&G 2024 Winter Investor Presentation, page 41
11.We note in slide 41 that you present adjusted net earnings that includes an adjustment
related to alternative investment returns below your long-term expectations. We
further note that you discuss this measure in your fourth quarter 2024 earning call. In
your response letter dated October 26, 2022, you stated that you “... revised the
disclosures... to remove this adjustment from all non-GAAP financial measures” since
this adjustment results in a misleading non-GAAP measure that violates Rule 100(b)
of Regulation G. Please discontinue disclosing measures that contain this adjustment
in all future public communications whether written or oral or tell us how your current
presentation in your earnings release and discussion of this measure in your earnings
call complies with Regulation G.
            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.
            Please contact Michael Volley at 202-551-3437 or Amit Pande at 202-551-3423 with
any questions.
Sincerely,
Division of Corporation Finance
Office of Finance