ERIEErie Indemnity

You disclose that you maintain an estimated allowance to reduce the management fee to its estimated net realizable value to account for the potential of mid-term policy cancellation based on historical cancellation rates.

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You go on to indicate that your historical cancellation rates were adjusted in 2020 to include the potential for increased cancellations given the current economic conditions related to the COVID-19 pandemic. Please provide us proposed revised disclosure to be included in future periodic reports that: • Removes discussion of an estimated allowance and an estimated net realizable value and instead incorporates the ASC 606 concepts of transaction price being constrained as stipulated in ASC 606-10-32-11 and that revenue recognized reflects the consideration to which you expect to be entitled as stipulated in ASC 606-10-10-2; and • Provides the quantitative disclosure about changes in transaction price associated with changes in the assessment of variable consideration as required by ASC 606-1050-10b or tell us why this disclosure is not warranted.

We will remove discussion of an estimated allowance and an estimated net realizable value in Note 3. Revenue and incorporate the concepts of transaction price being constrained and that revenue recognized reflects the consideration to which we expect to be entitled. We respectfully propose enhancing the disclosure as highlighted in bold in Exhibit A in future periodic reports.

We evaluated the need for quantitative disclosure about changes in transaction price associated with the changes in the assessment of the variable consideration as required by ASC 606-10-50-10b.

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We concluded the cumulative catch-up adjustment to revenue that affected the corresponding contract liability was not significant for disclosure. We will continue to evaluate the need for quantitative disclosure in future filings and will incorporate any required quantitative disclosures, if significant.

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Please provide us proposed revised disclosure to be included in future periodic reports for contract liabilities in the form of your deferred revenue that: • Indicates the amount of revenue recognized in the reporting period that was included in deferred revenue at the beginning of the period as required by ASC 606-10-50-8b; • Explains when you expect to recognize as revenue your deferred revenue as required by ASC

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606-10-50-13b. Otherwise, tell us why these disclosures are not warranted.

We respectfully propose enhancing the disclosure in Note 3. Revenue to include the amount of revenue recognized in the reporting period that was included in deferred revenue at the beginning of the period in accordance with ASC 606-10-50-8b as highlighted in bold in Exhibit A.

The explanation of when we expect to recognize our deferred revenue as revenue was disclosed in Note 2. Significant Accounting Policies, recognition of management fee revenue. We recognize the additional transparency provided by also including the information in Note 3. Revenue.

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We respectfully propose enhancing our disclosure in Note 3. Revenue, as highlighted in bold in Exhibit A.

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