June 11, 2018
Dairen Lin
President and Executive Director
China Life Insurance Company Limited
16 Financial Street
Xicheng District
Beijing 100033
China
Re: China Life Insurance Company Limited
Form 20-F for the Fiscal Year Ended December 31, 2017
Filed April 25, 2018
File No. 001-31914
Dear Mr. Lin:
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 10 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 20-F for the Fiscal Year Ended December 31, 2017
Item 5. Operating and Financial Review and Prospects
Factors Affecting Our Results of Operations
Investments, page 91
1. Please address the following regarding your available for sale
investments in the tables on
page 93:
Explain to us the reason for the increase in fair value of debt
securities in an unrealized
loss position for more than one year to RMB 45.8 billion at December
31, 2017
compared to December 31, 2016 and the reason for the increase in the
related
unrealized losses both in terms of renminbi amount and as a percentage
of the fair
Dairen Lin
FirstName LastNameDairen LinLimited
China Life Insurance Company
Comapany NameChina Life Insurance Company Limited
June 11, 2018
Page 2
June 11, 2018 Page 2
FirstName LastName
value of those debt securities. Provide your explanations
segregated by the types of
securities presented in the first table on page 93 (e.g.,
government bonds, government
agency bonds, etc.).
Reconcile for us why the RMB 3,562 million difference between the
aggregate cost/amortized cost at December 31, 2017 of RMB 814,296
million and the
aggregate estimated fair value of RMB 810,734 million is not the
same as the RMB
1,717 million net unrealized losses derived from the disclosed
gross unrealized gains
of RMB 25,120 million net of gross unrealized losses of RMB 26,837
million.
B. Liquidity and Capital Resources
Contractual Obligations and Commitments, page 124
2. According to your disclosure following the table on page 124, you
include both cash
inflows and cash outflows associated with insurance contracts and
investment contracts in
your table. Please tell us how your net presentation complies with
Item 5F of Form 20-F
and the nature of and amount of cash inflows netted in each column for
each of these line
items in your table.
Notes to the Consolidated Financial Statements
Note 4: Risk Management
Note 4.3: Fair value hierarchy, page F-48
3. Please address the following comments regarding your fair value and
fair value hierarchy
disclosures:
Tell us how your disaggregation of your investments into only debt
securities and
equity securities qualifies as appropriate classes under paragraph
94 of IFRS 13 and
paragraph 6 of IFRS 7. In this regard, it appears that your
disaggregation presented in
the first table on page 93 may be more appropriate.
Tell us why you do not provide information in your tables beginning
on page F-49 for
your held-to-maturity securities. In this regard, paragraph 97 of
IFRS 13 requires the
disclosure of some information from paragraph 93 of that standard
for each class of
assets and liabilities not measured at fair value on your balance
sheet if fair value
information is required to be disclosed by another standard. It
appears that paragraph
25 of IFRS 7 requires fair value information for all financial
assets and liabilities, not
just those carried at fair value on either a recurring or
non-recurring basis.
Tell us your consideration for disclosing the specific valuation
techniques used to
value each class of your Level 2 investments and the related
inputs as stipulated in
paragraph 93(d) of IFRS 13.
Tell us why you do not appear to provide the quantitative
information about the
significant unobservable inputs used in the fair value measurement
of your Level
3 investments as required by paragraph 93(d) of IFRS 13. To the
extent you rely upon
the further guidance in that paragraph indicating that you are not
required to create the
quantitative information if it is supplied by a third-party
pricing service, tell us how
Dairen Lin
China Life Insurance Company Limited
June 11, 2018
Page 3
the quantitative information is not reasonably available to you
considering your
disclosure in the second paragraph on page F-48 indicating the
validation procedures
you undertake associated with values received from pricing
services.
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 Keira Nakada at (202)
551-
36359 with any questions.
FirstName LastNameDairen Lin
Comapany NameChina Life Insurance Company Limited
Division of
Corporation Finance
June 11, 2018 Page 3 Office of
Healthcare & Insurance
FirstName LastName