SEC Comment Letter for F&G Annuities & Life, (FG) — Jul 11, 2025
F&G Annuities & Life, Inc.
Date: July 11, 2025 · CIK: 0001934850 · Accession: 0000000000-25-007299
AI Filing Summary & Sentiment
File numbers found in text: 001-41490
Letter
July 11, 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 Response dated July 7, 2025 File No. 001-41490 Dear Conor Murphy : We have reviewed your July 7, 2025 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 June 20, 2025 letter. Response dated July 7, 2025 Non-GAAP Financial Measures, page 87 1.We note your response to prior comment 1. Please explain to us in detail what the MRB Discrete Asset method is and why it is an appropriate methodology to amortize the deferred portion of the changes in fair value of market risk benefits into adjusted net earnings. We note your response to prior comment 1. Please tell us how you considered whether recognizing the deferred portion of the changes in fair value of market risk benefits into adjusted net earnings through the MRB Discrete Asset amortization method was more appropriate than recognizing the deferred portion through the recognition of the MRB attributed fees when earned and the GMxB benefits when contractually due through US GAAP earnings which appears to be similar to options A and B discussed on page 5 of your response. Clarify why the second method detailed above does not 2.
July 11, 2025 Page 2 recognize the economic impact to the MRB in adjusted net earnings which you appear to assert in your discussion of options A & B on page 5 of your response. Please contact Michael Volley at 202-551-3437 or Amit Pande at 202-551-3423 if you have questions. Sincerely, Division of Corporation Finance Office of Finance
Show Raw Text
July 11, 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
Response dated July 7, 2025
File No. 001-41490
Dear Conor Murphy :
We have reviewed your July 7, 2025 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 June 20,
2025 letter.
Response dated July 7, 2025
Non-GAAP Financial Measures, page 87
1.We note your response to prior comment 1. Please explain to us in detail what the
MRB Discrete Asset method is and why it is an appropriate methodology to amortize
the deferred portion of the changes in fair value of market risk benefits into adjusted
net earnings.
We note your response to prior comment 1. Please tell us how you considered whether
recognizing the deferred portion of the changes in fair value of market risk benefits
into adjusted net earnings through the MRB Discrete Asset amortization method was
more appropriate than recognizing the deferred portion through the recognition of the
MRB attributed fees when earned and the GMxB benefits when contractually due
through US GAAP earnings which appears to be similar to options A and B discussed
on page 5 of your response. Clarify why the second method detailed above does not 2.
July 11, 2025
Page 2
recognize the economic impact to the MRB in adjusted net earnings which you appear
to assert in your discussion of options A & B on page 5 of your response.
Please contact Michael Volley at 202-551-3437 or Amit Pande at 202-551-3423 if
you have questions.
Sincerely,
Division of Corporation Finance
Office of Finance