SecProbe.io

Filing text and metadata
Intelligence Terminal Search Probe Scores Topics IPO Watchlist Monthly Activity About API

SEC Comment Letter for MITSUBISHI UFJ FINANCIAL GROUP INC (MUFG, MBFJF) (CIK 0000067088) (MUFG) — Apr 1, 2016

MITSUBISHI UFJ FINANCIAL GROUP INC (MUFG, MBFJF) (CIK 0000067088)
Date: April 1, 2016 · CIK: 0000067088 · Accession: 0000000000-16-070646

AI Filing Summary & Sentiment

Date
March 31, 2016
Author
/s/ Christian Windsor
Form
UPLOAD
Company
MITSUBISHI UFJ FINANCIAL GROUP INC (MUFG, MBFJF) (CIK 0000067088)

Letter

Mail Stop 4720 March 31, 2016 Nobuyuki Hirano 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 Fiscal Year Ended March 31, 2015 Filed July 27, 2015 File No. 0-54189

Dear Mr. Hirano :

We have reviewed your filing an d have the following comment. In our comment, we may ask you to provide us with information so we may better understand your disclosure.

Please respond to this comment within ten busine ss days by providing the requested information or advis e us as soon as possible when you will respond. If you do not believe our comment appl ies to your facts and circumstances , please tell us why in your response.

After reviewing your response to this comment, we may have additional comments.

Note 26 – Commitments and Contingent Liabilities – Litigation, page F -128

1. Please explain to us how your disclosure of legal proceedings on page 165 and your risk factor related to legal proceedings on page 12 reflect the investigations related to your involvement in setting interbank benchmark rates and putative class actions in the United States. Based on the guidance in ASC 450 -20-50, for those particular loss contingencies with at least a reasonable possibility that a loss exceeding amounts already recognized may have been incurred, please revise future filings to disclose the nature of the contingency a nd:

 the amount or range of reasonably possible losses in excess of amounts accrued,  that reasonably possible losses cannot be estimated, or  that any reasonably possible losses in addition to amounts accrued is not material to your financial statements.

Nobuyuki Hirano Mitsubishi UFJ Financial Group, Inc. March 31 , 2016 Page 2

If you conclude that you cannot estimate the reasonably possible additional loss or range of loss, please:

 explain to us the procedures you undertake to attempt to develop a range of reasonably possible loss for disclosure, and  for each material matter, what specific factors are causing the inability to estimate and when you expect those factors to be alleviated.

We recognize that there are a number of uncertainties and potential outcomes associated with loss contingencies. We believe an effort should be made to develop estimates for purposes of disclosure, including determining which of the potential outcomes are reasonably possible and what the reasonably possible range of losses would be for those reasonably possible outcomes. In this regard, you ma y provide your disclosures on an aggregated basis.

We urge all persons who are responsible for the accuracy and adequacy of the disclosure in the filing to be certain that the filing includes the information the Securities Exchange Act of 1934 and all app licable Exchange Act rules require. 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.

In responding to our comm ents, 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

 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.

Nobuyuki Hirano Mitsubishi UFJ Financial Group, Inc. March 31 , 2016 Page 3

Please conta ct Michael Volley , Staff Accountant, at 202-551-3437 or John Nolan, Senior Assistant Chief Accountant, at (202) 551 -3492 if you have questions regarding comments on the financial statements and related matters . Please contact Alexandra M. Ledbetter, Staff Attorney, at (202) 551 -3317 or me at (202) 551 -3419 with any other questions.

Sincerely,
/s/ Christian Windsor

Show Raw Text
Mail Stop 4720

March 31, 2016

Nobuyuki Hirano
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 Fiscal Year Ended March 31, 2015
Filed July 27, 2015
File No. 0-54189

Dear Mr. Hirano :

We have reviewed your filing an d have the following comment.  In our comment, we
may ask you to provide us with information so we may better understand your disclosure.

Please respond to this comment  within ten busine ss days by providing the requested
information or advis e us as soon as possible when you will respond.  If you  do not believe our
comment appl ies to your facts and circumstances , please tell us why in your response.

After reviewing your response to this comment, we may have  additional comments.

Note 26 – Commitments and Contingent Liabilities – Litigation, page F -128

1. Please explain to us how your  disclosure of legal proceedings on page 165 and your risk
factor related to legal proceedings on page 12 reflect the investigations related to your
involvement in setting interbank benchmark rates and putative class actions in the United
States.  Based on  the guidance in ASC 450 -20-50, for those particular loss contingencies
with at least a reasonable possibility that a loss exceeding amounts already recognized
may have been incurred, please revise future filings to disclose the nature of the
contingency a nd:

 the amount or range of reasonably possible losses in excess of amounts accrued,
 that reasonably possible losses cannot be estimated, or
 that any reasonably possible losses in addition to amounts accrued is not material to your
financial statements.

Nobuyuki Hirano
Mitsubishi UFJ Financial Group, Inc.
March 31 , 2016
Page 2

 If you conclude that you cannot estimate the reasonably possible additional loss or range
of loss, please:

 explain to us the procedures you undertake to attempt to develop a range of reasonably
possible loss for disclosure, and
 for each material matter, what specific factors are causing the inability to estimate and
when you expect those factors to be alleviated.

We recognize that there are a number of uncertainties and potential outcomes associated
with loss contingencies.  We believe an effort should be made to develop estimates for
purposes of disclosure, including determining which of the potential outcomes are
reasonably possible and what the reasonably possible range of losses would be for those
reasonably possible outcomes.  In this regard, you ma y provide your disclosures on an
aggregated basis.

We urge all persons who are responsible for the accuracy and adequacy of the disclosure
in the filing to be certain that the filing includes the information the Securities Exchange Act of
1934 and all app licable Exchange Act rules require.   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.

 In responding to our comm ents, 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

 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.

Nobuyuki Hirano
Mitsubishi UFJ Financial Group, Inc.
March 31 , 2016
Page 3

 Please conta ct Michael Volley , Staff Accountant,  at 202-551-3437  or John Nolan, Senior
Assistant Chief Accountant, at (202) 551 -3492 if you have questions regarding comments on the
financial statements and related matters .  Please contact Alexandra M. Ledbetter, Staff  Attorney,
at (202) 551 -3317  or me at (202) 551 -3419 with any other questions.

Sincerely,

 /s/ Christian Windsor

 Christian Windsor
Special Counsel
Office of Financial Services

CC: Via E -Mail
 Tong Yu
 Paul, Weiss, Rifkin d, Wharton , Garrison LLP