United States securities and exchange commission logo October 17, 2022 Peter C. Enns Chief Financial Officer Chubb Ltd Baerengasse 32 Zurich, Switzerland CH- 8001 Re: Chubb Ltd Definitive Proxy Statement on Schedule 14A Filed April 4, 2022 File No. 001-11778 Dear Peter C. Enns: We have completed our review of your filing. 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. Sincerely, Division of Corporation Finance Disclosure Review Program