SEC Comment Letter for POLAND REPUBLIC OF (CIK 0000079312) — Sep 30, 2022
POLAND REPUBLIC OF (CIK 0000079312)
Date: Sept. 30, 2022 · CIK: 0000079312 · Accession: 0000000000-22-010815
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File numbers found in text: 333-267287
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United States securities and exchange commission logo
September 30, 2022
Sebastian Skuza
Secretary of State
POLAND REPUBLIC OF
Consul General of the Republic of Poland
233 Madison Ave
New York, NY 10016
Re:State Treasury of the Republic of Poland
Schedule B filed on September 6, 2022
File No. 333-267287
Dear Mr. Skuza:
We have reviewed your registration statement 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 registration statement and providing the
requested 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.
Schedule B
The Economy, page 15
1.We note your disclosure that certain data are not entirely comparable to 2021 data due to
changes in methodology. To the extent possible, describe the change in methodology
and/or the material impact that such change would have on the more recent data.
Meeting of Holders of Debt Securities; Modification, page 63
2.On page 64, the prospectus discusses certain types of collective action clauses. Please
identify the collective action clause provisions under a separate caption or refer to the
collective action clauses in the current caption.
FirstName LastNameSebastian Skuza
Comapany NamePOLAND REPUBLIC OF
September 30, 2022 Page 2
FirstName LastName
Sebastian Skuza
POLAND REPUBLIC OF
September 30, 2022
Page 2
Exhibits, Legal Opinion, page II-4
3.We note your representation in Part II that the issuer agrees to furnish a copy of the
opinion of the Director of the Legal Department of the Ministry of Finance, Republic of
Poland as to the legality of each issue of the securities. Please confirm to us that you will
file clean legal opinions of all relevant parties as to the legality of the issue of the
securities at the time of each takedown.
General
4.To the extent possible, please update all information and statistics in the registration
statement to provide the most recent data possible. This may include, for example, your
use of "preliminary data" throughout the prospectus.
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.
Refer to Rules 460 and 461 regarding requests for acceleration. Please allow adequate
time for us to review any amendment prior to the requested effective date of the registration
statement.
Please contact Katherine Hsu, Special Counsel, at 202-551-5243 or Michael Coco, Office
Chief, at 202-551-3253 with any questions.
Sincerely,
Division of Corporation Finance
Office of International Corporate
Finance