SEC Comment Letter for REPUBLIC OF CHILE (CIK 0000019957) — Jan 9, 2020
REPUBLIC OF CHILE (CIK 0000019957)
Date: Jan. 9, 2020 · CIK: 0000019957 · Accession: 0000000000-20-000228
AI Filing Summary & Sentiment
File numbers found in text: 001-02574, 333-235463
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January 8, 2020
Via E -mail
Francisco Del Campo Lagos
Consul General of the Republic of Chile
600 Third Avenue #2808
New York, New York 10016
Re: Republic of Chile
Registration Statement under Schedule B
Filed December 12 , 201 9
File No. 333-235463
Form 18 -K for Fiscal Year Ended December 31, 201 8
Filed May 8 , 201 9
Amended June 17, 2019, June 25, 2019 and July 7, 2019
File No. 001-02574
Dear Mr. Lagos :
We have reviewed your filing s 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 this letter by amending your documents and providing the requeste d
information. If you do not believe our comments apply to your facts and circumstances or do not
believe an amendment is appropriate, please tell us why in your response.
After reviewing any amendment to your registration statement and the information you
provide in response to these comments, we may have additional comments.
General
1. To the extent possible, please update all statistics and information to provide the most
recent data.
2. We note numerous news reports regarding various strikes, the income inequality
facing your country, and a recent drought. Please update your disclosure or
include a recent developments section, as necessary, to discuss the material
economic, political and other effects of these issues.
Francisco Del Campo Lagos
January 8, 2020
Page 2
3. We note reports of the recent increase in relative debt affecting your credit rating.
Please include a discussion of any risks related to any increase in debt that you may
incur.
Schedule B
Exhibit 99.G
4. Please delete the reference to “further assumptions and qualifications,” in the
penultimate paragraph on page two and ensure that the opinion makes clear the
assumptions and qualifications upon which it is based .
Form 18 -K
5. We are unable to locate Exhibit 99.C. Please advise.
Exhibit 99.D
6. To the extent practicable, please ensure that your statistical charts covering various
periods are accompanied with narrative disclosures that discuss the material changes
and provide an explanatory basis for the changes.
7. Please tell us why you have not included certain data for various years in the chart
under “Public Sector Finances” on page D -97.
8. Please revise your disclosure on page D -101 to describe the criteria in Article 41(h)
that you reference.
Closing Comment
We remind you that you are responsible for the accuracy and adequacy of the disclosures,
notwithstanding any review, comments, action or absence of action by the staff.
Refer to Rules 460 and 461 regarding requests for acceleration. Please allow adequa te
time for us to review any amendment prior to the requested effective date of the registration
statement.
Please contact Corey Jennings, Special Counsel, at (202) 551 -3258 or Michael Coco,
Chief, at (202) 551 -3253 with any questions.
Since rely,
Division of Corporation Finance
Office of International Corporate
Finance
Francisco Del Campo Lagos
January 8, 2020
Page 3
cc: Andrés de la Cruz, Esq.
Cleary Gottlieb Steen & Hamilton LLP