AJGArthur J. Gallagher & Co.

Change in Presentation of Fiduciary Assets and Liabilities, page 89 1. We note your disclosure that you revised your balance sheet and statement of cash flows presentation to separately identify and present fiduciary assets and liabilities and that you also made certain revisions to fiduciary balances related to the former Willis Re operations from gross to net presentation to align with your accounting policy and

Rest of the question

presentation. For each change and revision reflected in the financial statements, please address the items below. • Clarify whether you concluded that your prior presentation (e.g., gross to net, statement of cash flow classification, etc.) was an error and how you considered ASC 250 in your determination. • To the extent applicable, provide us with a detailed description of any error(s), including but not limited to who identified them, when and how, whether they were the result of control deficiencies, as well as your assessment of materiality, individually and in the aggregate, that addresses both qualitative and quantitative factors and consideration of guidance in ASC 250, SAB 99, and management's assessment of design and effectiveness of ICFR. • Provide us with an accounting analysis, citing authoritative literature, explaining your presentation before and after implementing these changes to your presentation. For example, explain why net change in fiduciary assets and liabilities appears to have moved from operating activities to financing activities within the statement of cash flows.

No numbered answer found in the reply. Read the reply ↗