Global Legal, Compliance, Regulatory Affairs and Government Affairs 80 Pine Street, 13th Floor New York, NY 10005 www.aig.com
James J. Killerlane III Associate General Counsel and Assistant Secretary T 212 770 8111 F 866 215 0326 james.killerlane@aig.com |
December 14, 2017
VIA EDGAR CORRESPONDENCE
Ms. Vanessa Robertson Office of Healthcare & Insurance Securities and Exchange Commission Division of Corporation Finance 100 F Street, NE Mail Stop 4720 Washington, D.C. 20549
Re: American International Group, Inc. Form 10-Q for the Quarterly Period Ended September 30, 2017 Filed November 3, 2017 File No. 1-08787 | |
Dear Ms. Robertson:
We are in receipt of your letter dated December 5, 2017 with respect to American International Group, Inc.s (AIG, we, or our) Quarterly Report on Form 10-Q for the quarterly period ended September 30, 2017 (Form 10-Q). This letter sets forth our response to the Staffs comment contained in your letter.
We have repeated your comment below to facilitate your review.
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Managements Discussion and Analysis of Financial Condition and Results of Operations Use of Non-GAAP Measures, page 73
1. After-tax operating income attributable to AIG and pre-tax operating income that you identify as non-GAAP measures appear to be titles that are the same as, or confusingly similar to, those used for GAAP financial measures and precluded by Item 10(e)(ii)(E) of Regulation S-K. As such, please confirm to us that you will revise the titles of these measures in future filings to provide an appropriate description for each measure that complies with Item 10(e).
AIG Response
We acknowledge the Staffs comment and hereby confirm that we will revise after-tax operating income attributable to AIG to adjusted after-tax income attributable to AIG and pre-tax operating income to adjusted pre-tax income in future filings, beginning with the 2017 Annual Report on Form 10-K. |
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If you have any questions or require any additional information, please do not hesitate to contact me at (212) 770-8111. |
Very truly yours, |
/s/ James J. Killerlane III |
Associate General Counsel |
and Assistant Secretary |
American International Group, Inc. |
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