August 15, 2024
Jane Wang
Senior Vice President and Chief Financial Officer
Loews Corporation
9 West 57th Street
New York, NY 10019-2714
Re: Loews Corporation
Form 10-K for Fiscal Year Ended December 31, 2023
File No. 001-06541
Dear Jane Wang:
We have limited our review of your filing to the financial statements
and related
disclosures 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.
Form 10-K for Fiscal Year Ended December 31, 2023
Property and Casualty Operations, page 47
1. We note your disclosure of underlying loss ratio and underlying
combined ratio on
page 47, which are presented as loss ratio excluding catastrophes and
development and
combined ratio excluding catastrophes and development,
respectively, in the table on
page 48. Please tell us how you determined that these ratios do not
constitute non-GAAP
financial measures considering these measures exclude the impact of
catastrophe losses
and development-related items. Refer to Rule 101(a) of Regulation G and
Question
100.05 of the Division of Corporation Finance's C&DI on Non-GAAP
Financial
Measures. Please revise future filings as applicable, also ensuring
consistent use of
terminology.
Altium Packaging, page 104
2. We note your disclosure on page 5 that you own 53% of Altium Packaging
in addition to
your disclosure on page 104 that you deconsolidated this subsidiary in
2021 when you
sold approximately 47% of Altium Packaging to GIC. Please explain in
further detail the
August 15, 2024
Page 2
certain participating rights with GIC related to capital allocation
and other decisions and
any other terms of the sale to GIC that resulted in your accounting for
your investment in
Altrium Packaging under the equity method of accounting, effective April
1, 2021.
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.
Please contact William Schroeder at 202-551-3294 or John Spitz at
202-551-3484 with
any questions.
Sincerely,
Division of
Corporation Finance
Office of Finance