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SEC Company Response from NORTHERN TRUST CORP (NTRS, NTRSO) (CIK 0000073124) (NTRS) — Sep 17, 2024

NORTHERN TRUST CORP (NTRS, NTRSO) (CIK 0000073124)
Date: Sept. 17, 2024 · CIK: 0000073124 · Accession: 0000073124-24-000223

Regulatory Compliance Financial Reporting Business Model Clarity

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File numbers found in text: 001-36609

Date
September 17, 2024
Author
Brad A. Kopetsky
Form
CORRESP
Company
NORTHERN TRUST CORP (NTRS, NTRSO) (CIK 0000073124)

Letter

seccorresp

Northern Trust Corporation 50 South La Salle Street Chicago, Illinois 60603 (312) 630-6000 September 17, 2024 VIA EDGAR TRANSMISSION Division of Corporation Finance Disclosure Review Program Securities and Exchange Commission 100 F Street, N.E. Washington, D.C. 20549 Attn: Jennifer Gowetski and Amanda Ravitz Re: Northern Trust Corporation Definitive Proxy Statement on Schedule 14A Filed March 6, 2024 File No. 001-36609 Ms. Gowetski and Ms. Ravitz: Northern Trust Corporation (the “Corporation”) acknowledges receipt of your letter, dated September 5, 2024, addressed to Michael G. O’Grady, Chairman and Chief Executive Officer of the Corporation, regarding the above referenced filing. As requested, the Corporation confirms that its future disclosures made pursuant to Item 402(v)(5) of Regulation S-K will address—graphically, narratively, or through a combination of the two—the specified relationships across the entire time horizon of the disclosure. Should you have any questions, please contact the undersigned at (312) 557-0200. Respectfully, NORTHERN TRUST CORPORATION /s/ Brad A. Kopetsky Brad A. Kopetsky Executive Vice President, Deputy General Counsel & Corporate Secretary

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CORRESP
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seccorresp

        Northern Trust Corporation  50 South La Salle Street  Chicago, Illinois 60603  (312) 630-6000      September 17, 2024    VIA EDGAR TRANSMISSION    Division of Corporation Finance  Disclosure Review Program  Securities and Exchange Commission  100 F Street, N.E.  Washington, D.C. 20549  Attn: Jennifer Gowetski and Amanda Ravitz      Re: Northern Trust Corporation  Definitive Proxy Statement on Schedule 14A   Filed March 6, 2024   File No. 001-36609    Ms. Gowetski and Ms. Ravitz:     Northern Trust Corporation (the “Corporation”) acknowledges receipt of your letter, dated September 5,  2024, addressed to Michael G. O’Grady, Chairman and Chief Executive Officer of the Corporation,  regarding the above referenced filing.     As requested, the Corporation confirms that its future disclosures made pursuant to Item 402(v)(5) of  Regulation S-K will address—graphically, narratively, or through a combination of the two—the specified  relationships across the entire time horizon of the disclosure.     Should you have any questions, please contact the undersigned at (312) 557-0200.        Respectfully,    NORTHERN TRUST CORPORATION     /s/ Brad A. Kopetsky         Brad A. Kopetsky   Executive Vice President,  Deputy General Counsel &   Corporate Secretary