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SEC Comment Letter for MITSUBISHI UFJ FINANCIAL GROUP INC (MUFG, MBFJF) (CIK 0000067088) (MUFG) — Mar 30, 2017

MITSUBISHI UFJ FINANCIAL GROUP INC (MUFG, MBFJF) (CIK 0000067088)
Date: March 30, 2017 · CIK: 0000067088 · Accession: 0000000000-17-010656

AI Filing Summary & Sentiment

Date
March 30, 2017
Author
/s/ Cecilia Blye
Form
UPLOAD
Company
MITSUBISHI UFJ FINANCIAL GROUP INC (MUFG, MBFJF) (CIK 0000067088)

Letter

Re: Mitsubishi UFJ Financial Group, Inc. Form 20 -F for the Fiscal Year Ended March 31, 2016 Filed July 15 , 2016 File No. 0-54189 Dear Mr. Hirano : We have limited our review of your filing to your contacts with countries that have been identified as state sponsor s of terrorism, and we have the following comments. Our review with respect to this issue does not preclude further review by the Assistant Director group with respect to other issues. At this juncture, we are asking you to provide us with information so we may better understand your disclosure.

March 30, 2017

Via E -mail Nobuyuki Hirano Presi dent and Group Chief Executive Officer Mitsubishi UFJ Financial Group, Inc. 7-1, Marunouchi 2 -chome, Chiyoda -ku Tokyo 100 -8330 , Japan

Please respond to this letter within ten business days by providing the requested information, or by advising us when you will provide the requested response. If you do not belie ve our comments apply to your facts and circumstances, please tell us why in your response.

After reviewing the information you provide in response to this comment, we may have additional comments.

General

1. In your letter to us dated January 27, 2014 you described your activities related to Sudan and Syria, countries which are designated by the U.S. Department of State as state sponsors of terrorism, and are subject to U.S. economic sanctions and export controls. Your Form 20-F does not include discl osure about contacts with those countries. Please describe to us the nature and extent of your past, current and anticipated contacts with Sudan and Syria since the referenced letter, whether through subsidiaries, affiliates, branches, offices or other di rect or indirect arrangements. You should describe any services, products, technology or support you have provided into Sudan and Syria, directly or indirectly, and any agreements, arrangements or other contacts you have had with the governments of those countries or entities they control.

Nobuyuki Hirano Mitsubishi UFJ Financial Group, Inc. March 30, 2017 Page 2

2. Please discuss the materiality of any contacts with Sudan and Syria you describe in response to the comment above, and whether the contacts constitute a material investment risk for your security holders. You should ad dress materiality in quantitative terms, including the approximate dollar amounts of any revenues, assets and liabilities associated with Sudan and Syria for the last three fiscal years and the subsequent interim period. Also, address materiality in terms of qualitative factors that a reasonable investor would deem important in making an investment decision, including the potential impact of corporate activities upon a company’s reputation and share value. As you know, various state and municipal governments, universities and other investors have proposed or adopted divestment or similar initiatives regarding investment in companies that do business with U.S. -designated state sponsors of terrorism. You should address the potential impact of the investor sentiment evidenced by such actions directed toward companies that have operations associated with Sudan and Syria .

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.

Please contact Pradip Bhaumik, Special Counsel, at (202) 551 -3333 or me at (202) 551 - 3470 if you have any questions about the comments or our review.

Sincerely,
/s/ Cecilia Blye

Show Raw Text
March 30, 2017

Via E -mail
Nobuyuki Hirano
Presi dent and Group 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 Fiscal Year Ended March  31, 2016
  Filed July 15 , 2016
  File No. 0-54189
Dear Mr. Hirano :
We have limited our review of your filing to your contacts with countries that have  been
identified as state sponsor s of terrorism, and we have the following comments.  Our review with
respect to this issue does not preclude further review by the Assistant Director group with respect
to other issues.   At this juncture, we are asking you to provide us with information so we may
better understand your disclosure.

Please respond to this letter within ten business days by providing the requested
information, or by advising us when you will provide the requested response.  If you do not
belie ve our comments apply to your facts and circumstances, please tell us why in your response.

After reviewing the information you provide in response to this comment, we may have
additional comments.

General

1. In your letter to us dated January 27, 2014  you described your activities related to Sudan
and Syria, countries which are designated by the U.S. Department of State as state sponsors
of terrorism, and are subject to U.S. economic sanctions and export controls.  Your Form
20-F does not include discl osure about contacts with those countries.  Please describe to us
the nature and extent of your past, current and anticipated contacts with Sudan and Syria
since the referenced letter, whether through subsidiaries, affiliates, branches, offices or
other di rect or indirect arrangements.  You should describe any services, products,
technology or support you have provided into Sudan and Syria, directly or indirectly, and
any agreements, arrangements or other contacts you have had with the governments of
those countries or entities they control.

Nobuyuki Hirano
Mitsubishi UFJ  Financial Group, Inc.
March 30, 2017
Page 2

 2. Please discuss the materiality of any contacts with Sudan and Syria you describe in
response to the comment above, and whether the contacts constitute a material
investment risk for your security holders. You should ad dress materiality in quantitative
terms, including the approximate dollar amounts of any revenues, assets and liabilities
associated with Sudan and Syria for the last three fiscal years and the subsequent interim
period.  Also, address materiality in terms of qualitative factors that a reasonable investor
would deem important in making an investment decision, including the potential impact
of corporate activities upon a company’s reputation and share value.  As you know,
various state and municipal governments, universities and other investors have proposed
or adopted divestment or similar initiatives regarding investment in companies that do
business with U.S. -designated state sponsors of terrorism.  You should address the
potential impact of the investor sentiment evidenced by such actions directed toward
companies that have operations associated with Sudan and Syria .

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.

Please contact Pradip Bhaumik, Special Counsel, at (202) 551 -3333 or me at (202) 551 -
3470 if you have any questions about the comments or our review.

         Sincerely,

         /s/ Cecilia Blye

         Cecilia Blye, Chief
         Office of Global Security Risk

cc:  Dietrich King
  Assistant Director
 Division of Corporation Finance