Executive Board | ||
J.B.M. Streppel | ||
Securities and Exchange Commission | ||
Attn. Mr. Jim B. Rosenberg | AEGON N.V. | |
Senior Assistant Chief Accountant | ||
Division of Corporation Finance | Postal address: | |
100 F Street, N.E. | P.O. Box 85 | |
Washington, DC 20549 | 2501 CB The Hague (The Netherlands) | |
USA | ||
Aegon N.V. visiting address: | ||
Bezuidenhoutseweg 273 | ||
2594 AN The Hague | ||
Telephone +31 70 344 32 10 | ||
Fax +31 70 347 52 38 | ||
Our reference | Your reference | The Hague | ||
| File number 001-10882 | October 1, 2008 | |||
Dear Mr. Rosenberg,
We thank you for your letter dated September 19, 2008 regarding the Annual Report on Form 20-F of AEGON N.V. (“AEGON”) for 2007 (“2007 Form 20-F”).
We set forth below our responses to the comments of the staff of the Division of Corporation Finance (“the Staff”) of the Securities and Exchange Commission (the “Commission”). The responses to your letter are numbered to correspond to the numbered comments in that letter.
Financial Statements
| 1. | Please confirm that you will provide the additional information included in your response to comments 1 and 2, including the supplemental information provided in response to comment 2 in your next Form 20-F. |
We confirm that we will provide the additional information in our 2008 Form 20-F. With regard to the table on primary price source as included in the supplemental information provided in response to comment 2, we are not planning to disclose this in our next Form 20-F.
We are of the opinion that this table does not provide useful disclosure to the users of the financial statements as it only relates to one input variable in our valuation process. We are of the opinion that the qualitative disclosure under comment 2 does give the users of the financial statements a balanced overview of AEGON’s valuation process. The additional and supplemental information related to monoline insurers exposures will be part of our disclosures as long as the severe credit market conditions make these disclosures relevant.
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Register The Hague no. 27076669
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If you have any questions or comments about the foregoing, please do not hesitate to contact me at + 31 70 344 8284 or Ruurd van den Berg, Executive Vice President Group Finance & Information, at + 31 70 344 8306.
| Very truly yours, |
/s/ Joseph B.M. Streppel |
| Joseph B.M. Streppel |
| Chief Financial Officer |