SEC Comment Letter for MITSUBISHI UFJ FINANCIAL GROUP INC (MUFG, MBFJF) (CIK 0000067088) (MUFG) — Jun 30, 2011
MITSUBISHI UFJ FINANCIAL GROUP INC (MUFG, MBFJF) (CIK 0000067088)
Date: June 30, 2011 · CIK: 0000067088 · Accession: 0000000000-11-039849
AI Filing Summary & Sentiment
File numbers found in text: 000-54189
Referenced dates: June 24, 2011
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June 30, 2011
Via E-mail
Katsunori Nagayasu President and Chief Executive Officer Mitsubishi UFJ Financial Group, Inc. 7-1, Marunouchi 2-chome, Chiyoda-ku Tokyo 100-8330 Japan
Re: Mitsubishi UFJ Financial Group, Inc.
Form 20-F for the year ended March 31, 2010 Filed August 16, 2010 Form 6-K Filed April 21, 2011 File No. 000-54189
Dear Mr. Nagayasu:
We have reviewed your response letter dated June 24, 2011, 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 within te n business days by providing the requested
information, or by advising us when you will provide the requested response. If you do not
believe our comments apply to your facts and circum stances, please tell us w hy in your response.
After reviewing the information you provide in response to these comments, we may
have additional comments. Form 20-F
General
1. As previously requested, please provide a written statement from the company
acknowledging that:
the company is responsible for the adequacy and accuracy of the disclosure in the
filing;
staff comments or changes to disclosure in response to staff comments do not
foreclose the Commission from taking any action with respect to the filing; and
Katsunori Nagayasu
Mitsubishi UFJ Financial Group, Inc. June 30, 2011 Page 2
the company may not assert staff comments as a defense in any proceeding initiated
by the Commission or any person under the federal securities laws of the United
States.
Risk Factors
“Because a large portion of our assets are locat ed in Japan and our business operations are
conducted primarily in Japan, we may incur further losses if economic conditions in Japan
worsen”, page 9
2. We have read your response to comment one. Given that you are unable to quantify the
loss directly caused by the ear thquake separately from losses caused by other economic
factors and that it will likely cause an indi rect adverse effect on your financial results,
please confirm that you plan to discuss how th e recent natural and nuclear disasters have
directly and indirectly impacted your operations, including a ny potential workouts or loan
restructurings you may make to borrowers signi ficantly affected by these events, in your
Form 20-F for the year ended March 31, 2011.
Item 11 – Quantitative and Qualitative Disclosu res about Credit, Market and Other Risk, page
142
Credit Risk Management, page 144
Borrower Rating, page 145
3. We have read your response to comment fi ve. Please confirm whether you plan to
expand your disclosure in future filings to discuss how you determine the expected debt-
service capability as well as the primary da ta reviewed when determining your borrower
rating system.
Note 31 – Fair Value, page F-121
Assets and Liabilities Meas ured at Fair Value on a N onrecurring Basis, page F-129
4. We have read your response to comments 15 and 16. Please confirm that you plan to
expand your disclosures in future filings to di scuss the different valu ation techniques and
assumptions used to value you the collateral underlyi ng these loans.
We urge all persons who are res ponsible for the accuracy and adequacy of the disclosure
in the filing to be certain that the filing include s the information the Securities Exchange Act of
1934 and all applicable Exchange Act rules requir e. Since the company and its management are
in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy
and adequacy of the disclosures they have made.
Katsunori Nagayasu
Mitsubishi UFJ Financial Group, Inc. June 30, 2011 Page 3
You may contact Yolanda Crit tendon, Staff Accountant at (2 02) 551-3472 or me at (202)
551-3512 with any other questions.
Sincerely,
/s/ Stephanie L. Hunsaker
Stephanie L. Hunsaker Senior Assistant Chief Accountant
cc: Mr. Tony Yu
Paul, Weiss, Rifkind, Wh arton & Garrison LLP