View:
United States securities and exchange commission logo
June 14, 2021
Mark Lyons
Chief Financial Officer
American International Group, Inc.
175 Water Street
New York, New York 10038
Re: American
International Group, Inc.
Form 10-K
Filed February 19,
2021
File No. 001-08787
Dear Mr. Lyons:
We have limited our review of your filing to the financial
statements and related
disclosures and have the following 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-K Filed February 19, 2021
Managements Discussion and Analysis of Financial Condition and Results
of Operations, page
49
1. We note your disclosure
on page 29 that upon the occurrence of certain triggers on the
part of Fortitude Re
under the applicable reinsurance agreements, your subsidiaries may
elect or may be
required, to recapture the business ceded under such reinsurance
agreements, which would
result in a substantial increase to your net insurance liabilities.
Please revise future
filings to discuss the nature of the triggers and provide additional
information regarding
the triggers to allow an investor to fully understand the uncertainty,
the likelihood of a
trigger occurring and the reasonably likely impact on financial
condition, results of
operations, liquidity or capital resources.
Sale of Fortitude Holdings, page 69
2. We note your disclosure
that the sale of Fortitude Re is subject to a post-closing purchase
Mark Lyons
FirstName LastNameMark Lyons
American International Group, Inc.
Comapany
June NameAmerican International Group, Inc.
14, 2021
June 14,
Page 2 2021 Page 2
FirstName LastName
price adjustment pursuant to which AIG will pay up to a maximum
payment of $500
million to Fortitude Re for certain adverse development in property
casualty related
reserves that may occur on or prior to December 31, 2023. We also note
your disclosure
on page 298, that you believe the likelihood that you will have to
make any material
payments is remote and no material liabilities have been recorded.
Please tell us the
accounting guidance you considered in accounting for the post-closing
purchase price
adjustment and revise future filings to disclose your accounting
policy, or tell us where it
is disclosed.
Financial Performance Summary, page 70
3. We note throughout your MD&A you discuss the business reasons for
changes in your
various financial results. In circumstances where there is more than
one business reason
for the change, please revise future filings to quantify the
incremental impact of each
significant individual business reason. Please refer to Item 303(a)(3)
of Regulation S-K
and SEC Release No. 33-8350 for guidance.
Business and Financial Highlights, page 89
4. We note your disclosure that during the second quarter of 2020, AIG
entered into a series
of quota share reinsurance agreements, including with Lloyd s
Syndicate 2019, a Lloyd s
syndicate managed by Talbot, to reinsure risks related to PCG which
caused net premiums
written to decrease in 2020. To the extent the Lloyd s Syndicate
arrangement is in the
scope of ASC 808, please provide us and revise future filings to
disclose the information
required by ASC 808-10-50-1. If you do not believe the arrangement is
in the scope of
ASC 808, please tell us how you account for the arrangement and
identify the relevant
accounting guidance and revise future filings to disclose your
accounting policies.
Consolidated Statements of Income (Loss), page 185
5. Based on disclosure on page 125, it appears you classify certain
unrealized activity
including changes in your allowance for credit losses and unrealized
changes in the fair
value of derivatives as realized in the Net realized capital gains
(losses) line item in the
consolidated statements of income (loss). If so, please revise you
current line item
description or revise your presentation to more accurately present the
nature of the gains
(losses).
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.
Mark Lyons
American International Group, Inc.
June 14, 2021
Page 3
You may contact Michael Volley, Staff Accountant, at 202-551-3437 or Amit
Pande,
Accounting Branch Chief at 202-551-3423 with any questions.
FirstName LastNameMark Lyons Sincerely,
Comapany NameAmerican International Group, Inc.
Division of Corporation
Finance
June 14, 2021 Page 3 Office of Finance
FirstName LastName