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United States securities and exchange commission logo
March 26, 2021
Mario Rizzo
Executive Vice President and Chief Financial Officer
The Allstate Corporation
2775 Sanders Road
Northbrook, Illinois 60062
Re: The Allstate
Corporation
Form 10-K for the
Fiscal Year Ended December 31, 2020
Filed February 22,
2021
Form 8-K Dated
February 3, 2021
Filed February 3,
2021
File No. 001-11840
Dear Mr. Rizzo:
We have limited our review of your filings 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 Fiscal Year Ended December 31, 2020
Notes to Consolidated Financial Statements
Note 4: Reportable Segments, page 142
1. In the table on page
145 you present more than one profit measure for each of your
segments; underwriting
income for your Property-Liability segments and adjusted net
income for all your
other segments as the first measure and net income applicable to
common shareholders for
each segment as the second measure. ASC 280-10-50-22
requires disclosure of
a single measure of segment profit or loss and ASC 280-10-50-28
indicates that when
more than one segment profit measure is utilized the one with the
measurement principles
most consistent with GAAP becomes the segment measure of
profit or loss. As a
result, please address the following:
Tell us which of
the two sets of measures is your single measure of segment profit or
Mario Rizzo
The Allstate Corporation
March 26, 2021
Page 2
loss and explain why, referencing the authoritative literature
you rely upon to support
your position.
Provide us proposed draft footnote disclosure to be included in
future periodic reports
that presents only that single measure of segment profit or loss
and reconciles this
measure to your consolidated income measure as required by ASC
280-10-50-30b.
Tell us whether you intend to continue to disclose the second
measure in your
Management's Discussion and Analysis and, to the extent you
anticipate doing so,
represent to us that you will identify it as a non-GAAP measure
and provide all the
disclosures required by Item 10(e)(1)(i) of Regulation S-K.
Form 8-K Filed February 3, 2021
Exhibit 99.1; Registrant's press release dated February 3, 2021
2. Please represent to us that in future earnings releases furnished on
Forms 8-K you will
revise your non-GAAP reconciliations on page 10 of this release to
show each reconciling
item before taxes and separately present and explain the aggregate
income tax impact of
the reconciling items. See Question 102.11 of the Compliance and
Disclosure
Interpretations for Non-GAAP Financial Measures.
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 Mark Brunhofer at (202)551-3638 or Sharon Blume at
(202)551-
3474 with any questions.
FirstName LastNameMario Rizzo Sincerely,
Comapany NameThe Allstate Corporation
Division of
Corporation Finance
March 26, 2021 Page 2 Office of
Finance
FirstName LastName