TEXT-EXTRACT 2 filename2.txt September 14, 2018 Martin Klein Executive Vice President and Chief Financial Officer Athene Holding Ltd 96 Pitts Bay Road Pembroke, HM08 Bermuda Re: Athene Holding Ltd Form 10-K for Fiscal Year Ended December 31, 2017 Filed February 26, 2018 File No. 001-37963 Dear Mr. Klein: We have completed our review of your filing. 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. Sincerely, Division of Corporation Finance Office of Healthcare & Insurance