Insurance companies have had no shortage of risks to face in 2023, and whether the cause is catastrophe losses, interest-rate changes, market disruptions, or inflation, the Division of Corporation Finance (CorpFin) of the Securities and Exchange Commission (SEC) is looking for disclosures that evolve to address these risks. The Sarbanes-Oxley Act of 2002 mandates CorpFin staff review registrant filings, including under both the Securities Act and the Exchange Act, at least once every three years. Each review might or might not result in a comment letter.
This report identifies themes from recent SEC comment letters for insurance industry registrants, and each section includes example SEC comments. We focus on insurance-specific topics, but we have also included sections for topics of frequent staff comment regardless of industry (for example, corporate governance and non-GAAP).
