CBChubb Limited

Please expand your discussion of the reasons you believe that your leadership structure is appropriate, addressing your specific characteristics or circumstances. In your discussion, please also address how the experience of your Lead Director is brought to bear in connection with your board’s role in risk oversight.

Reference is made to your letter (the “Comment Letter”), dated September 2, 2022, setting forth comments of the staff of the Division of Corporation Finance (the “Staff”) of the Securities and Exchange Commission in connection with the Staff’s limited review of the definitive proxy statement of Chubb Limited (the “Company”) that was filed with the Commission on April 4, 2022. The Company confirms that it will continue to enhance its disclosures in future proxy statements to reflect the topics discussed in the Comment Letter based on the SEC proxy statement disclosure regulations and guidance in effect at such time, as well as on the facts and circumstances applicable to the Company. One letter for all the questions, without numbered answers. Read the reply ↗

Please expand upon the role that your Lead Director plays in the leadership of the board. For example, please enhance your disclosure to address whether or not your Lead Director may: • require board consideration of, and/or override your CEO on, any risk matters; or • provide input on design of the board itself.

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Please expand upon how your board administers its risk oversight function. For example, please disclose: • the timeframe over which you evaluate risks (e.g., short-term, intermediate-term, or long-term) and how you apply different oversight standards based upon the immediacy of the risk assessed; • whether you consult with outside advisors and experts to anticipate future threats and trends, and how often you

Rest of the question

re-assess your risk environment; • how the board interacts with management to address existing risks and identify significant emerging risks; • to whom the Chief Compliance Officer reports; and • how your risk oversight process aligns with your disclosure controls and procedures.

See the reply above.