April 29, 2019
Philip Bancroft
Executive Vice President and Chief Financial Officer
Chubb Ltd
1133 Avenue of the Americas
Floor 41
New York, NY 10036
Re: Chubb Ltd
Form 10-K for the Fiscal Year Ended December 31, 2018
Filed February 28, 2019
Form 8-K dated February 5, 2018
Filed February 5, 2019
File No. 001-11778
Dear Mr. Bancroft:
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 for the year ended December 31, 2018
Notes to Consolidated Financial Statements
6. Unpaid losses and loss expenses
c) Loss Development Tables , page F-47
1. Please represent to us that in future filings you will include "reported
claims" as a column
within the "Net Incurred Loss and Allocated Loss Adjustment Expenses"
tables rather
than within the "Net Cumulative Paid Loss and Allocated Loss Adjustment
Expenses"
tables. Refer to ASC 944-40-50-4D and ASC 944-40-55-9E.
Philip Bancroft
FirstName LastNamePhilip Bancroft
Chubb Ltd
Comapany NameChubb Ltd
April 29, 2019
Page 29,
April 2 2019 Page 2
FirstName LastName
Form 8-K dated February 5, 2019
Exhibit 99.2
Regulation G--Non-GAAP Financial Measures
Core Operating Income measures, page 33
2. We refer to your non-GAAP measure "Core operating income excluding
catastrophe
losses" and as further adjusted to exclude prior period development as
well as your
rationale discussed on page 31 for presenting these non-GAAP measures.
While we note
that you generally define loss events as catastrophic if they cause
damage of $25 million
or more and affect a certain number of insureds (consistent with the
definition of the
Property Claims Service), it appears that the nature of these losses
are integral to your
operating results. Please tell us how you considered Question 100.01
of the Non-GAAP
Compliance and Disclosure Interpretations. Further, by excluding prior
year development
expenses recognized in the current period, it appears that you may be
substituting
individually tailored recognition and measurement methods for those of
GAAP. Please
tell us how you considered Question 100.04 of the Non-GAAP Compliance
and
Disclosure Interpretations
3. We refer to your non-GAAP measure "Core operating income with expected
level of
catastrophe losses" which excludes catastrophe losses above or below
management's view
of typical catastrophe losses for that period. The adjustment is
intended to present a
performance measure with normalized catastrophe activity. By excluding
a portion of the
losses incurred, it appears that you have substituted individually
tailored recognition and
measurement methods for those of GAAP. Please tell us how you
considered Question
100.04 of the Non-GAAP Compliance and Disclosure Interpretations
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.
You may contact Christine Allen Torney at 202-551-3652 or Jim Rosenberg
at 202-551-
3679 with any questions.
Sincerely,
Division of
Corporation Finance
Office of
Healthcare & Insurance