Genworth Financial, Inc.

Date: 4/3/09; 5/8/09; 6/12/09; 7/13/09; 8/17/09

SIC No.: 6311 Subject Filing: 10-K

State: DE

Accession No. (Staff Letter): 0000000000-09-017378; 0000000000-09-031410; 0000000000-09-044949

Accession No. (Co. Letter): 0001193125-09-105593; 0001193125-09-148175

The staff, upon reviewing the Form 10-K filed by Genworth Financial, Inc., inquired further regarding the company's re-estimation of certain liabilities for policy and contract claims. In particular, the staff asked Genworth to explain any re-estimates in its U.S. mortgage insurance business as well as to quantify material changes in delinquencies and foreclosures for each book of business for which prior year reserves were increased. The company, in its initial reply, observed that it maintains reserves for the cost of settling claims for insured events that occur within a specified reporting period. The company also noted that its U.S. mortgage insurance business was primarily responsible for the increased 2008 liability for policy and contract claims. The increase in liability, Genworth explained, was due to the deteriorating economic conditions in the U.S. housing market which produced increased delinquencies and foreclosures. The company's 2006 and 2007 books of business were especially hard hit. As a result, the company significantly increased the amount of reserves for its 2008, 2007, and 2006 books of business based upon its re-estimation of prior year insured events. The increased reserves were necessary to deal with deteriorating cure rates and aging of delinquencies likely to become claims. The company further noted that the trends justifying the revised estimates and increased reserves were unforeseeable prior to the economic turmoil in 2008.

In a follow-up comment, the staff asked Genworth to quantify the key assumptions it made regarding cure rates and aging of delinquencies. The staff also requested that the company discuss how it incorporated the changed assumptions into its liability for policy and contract claims for the relevant periods. Genworth replied that it would make the requested amendments in its next Form 10-K. Specifically, Genworth stated that it would provide the requested quantification of its changed assumptions. The company also revised its earlier proposed disclosure to state that the need to boost reserves was "entirely" rather than "primarily" due to increased levels of expected claim frequencies arising from the aging of delinquencies which were expected to become claims. The company applied the higher frequency assumptions to delinquencies in 2008 in order to determine its liability for policy and contract claims as of December 31, 2008. The staff subsequently indicated that it had no further comments.