United States securities and exchange commission logo





                            October 30, 2023

       Martin P. Klein
       Chief Financial Officer
       Athene Holding Ltd
       Second Floor, Washington House
       16 Church Street
       Hamilton, HM 11, Bermuda

                                                        Re: Athene Holding Ltd
                                                            Form 10-K for the
Fiscal Year Ended December 31, 2022
                                                            Response dated
September 29, 2023
                                                            File No. 001-37963

       Dear Martin P. Klein:

              We have reviewed your September 29, 2023 response to our comment
letter and have the
       following comments.

              Please respond to this letter 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 a
       comment applies to your facts and circumstances, please tell us why in
your response.

              After reviewing your response to this letter, we may have
additional comments. Unless
       we note otherwise, any references to prior comments are to comments in
our September 18,
       2023 letter.

       Form 8-K dated August 7, 2023

       Exhibit 99.1
       Selected Income Statement Data, page 4

   1.                                                   We note your response
to comment three, in which you state that your alternative
                                                        investment portfolio
has returned approximately 12%, on average, over the past ten years
                                                        and that you have based
your expectation of returns on this and adjusted down to 11% for
                                                        conservatism. Please
address the items below.
                                                            Explain the reasons
and factors you considered in determining that ten years is an
                                                            appropriate
lookback period and how your average and estimated rates of return
                                                            would be affected
by a different (longer or shorter) period.
                                                            Tell us how your
long-term expectation of returns for this asset class has compared to
                                                            actual returns and
how you determined that the prior ten years would be reflective of
 Martin P. Klein
Athene Holding Ltd
October 30, 2023
Page 2
              forward-looking long-term performance expectations.
                Explain how you determined that 11% is an appropriate
adjustment level for
              conservatism, as well as whether you adjust this level and, if
so, under what
              circumstances.
2.       In addition to the above, please provide us with a more fulsome
explanation of your
         rationale and considerations in determining that this normalization
adjustment is not
         individually tailored accounting. For example, your response states
that your adjustment
         does not change the recognition and measurement principles; however,
it is still unclear to
         us how you reached this conclusion, given that actual recognition and
measurement of
         alternative investment income, as reflected in your financial
statements under U.S. GAAP,
         are not fixed at 11%.
       Please contact Michael Henderson at 202-551-3364 or Cara Lubit at
202-551-5909 if you
have questions regarding comments on the financial statements and related
matters.



FirstName LastNameMartin P. Klein                              Sincerely,
Comapany NameAthene Holding Ltd
                                                               Division of
Corporation Finance
October 30, 2023 Page 2                                        Office of
Finance
FirstName LastName