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United States securities and exchange commission logo
July 6, 2023
Edward Spehar
Executive Vice President and Chief Financial Officer
Brighthouse Financial, Inc.
11225 North Community House Road
Charlotte, North Carolina 28277
Re: Brighthouse
Financial, Inc.
Form 10-K Filed
February 23, 2023
Form 10-Q Filed May
9, 2023
File No. 001-37905
Dear Edward Spehar:
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 Filed February 23, 2023
Note 10. Equity - Statutory Financial Information, page 174
1. Please tell us and
revise future filings to disclose the amount of statutory capital and
surplus necessary to
satisfy regulatory requirements. Refer to ASC 944-505-50-1 for
guidance.
2. We note the disclosure
throughout your filing related to your use of combined RBC.
Please tell us and
revise future filings to discuss how combined RBC is used by your
regulators. If it is
not used, please revise to expand on why you use the measure.
Form 10-Q Filed May 9, 2023
Non-GAAP Financial Disclosures, page 63
3. We note your
reconciliation of net income/(loss) available to shareholders to adjusted
earnings on page 66.
Please provide us detail of the underlying adjustments in the Other
Edward Spehar
Brighthouse Financial, Inc.
July 6, 2023
Page 2
adjustments reconciling item for each quarter presented and provide
us relevant facts and
circumstances to explain what the items represent and why you adjust
for them.
4. Please tell us and revise future filings to disclose how you calculate
the provision for
income tax related to your adjusted earnings Non-GAAP measure.
5. Please tell us how you considered whether each of the change in market
risk benefits
adjustments and the other adjustments used to calculate adjusted
earnings have the effect
of changing the recognition and measurement principles required to be
applied in
accordance with GAAP. Additionally, please tell us if you believe the
resulting
consolidated measure of adjusted earnings is misleading and violates
Rule 100(b) of
Regulation G. Please refer to Questions 100.04 and 104.04 of the
Compliance and
Disclosure Interpretations on Non-GAAP Financial Measures for
guidance.
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 Michael Volley at (202) 551-3437 or Amit Pande at (202)
551-
3423 with any questions.
FirstName LastNameEdward Spehar Sincerely,
Comapany NameBrighthouse Financial, Inc.
Division of
Corporation Finance
July 6, 2023 Page 2 Office of
Finance
FirstName LastName