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SEC Comment Letter 0000000000-25-009146 to UNITED MEXICAN STATES (CIK 0000101368)

UNITED MEXICAN STATES (CIK 0000101368)
Date: Aug. 26, 2025 · CIK: 0000101368 · Accession: 0000000000-25-009146

AI Filing Summary & Sentiment

Sentiment
Urgency
Document Type
Confidence
SEC Posture
Company Posture

Summary

Reasoning

File numbers found in text: 333-03610

Referenced dates: August 6, 2025

Date
August 26, 2025
Author
Division of
Form
UPLOAD
Company
UNITED MEXICAN STATES (CIK 0000101368)

Letter

Re: United Mexican States Draft Registration Statement under Schedule B Submitted July 11, 2025 CIK No. 0000101368 _ Form 18-K for fiscal year ended December 31, 2024 Filed June 20, 2025, amended July 2, 2025, July 22, 2025 and August 19, 2025 File No. 333-03610 Dear Mar a del Carmen Bonilla Rodr guez:

August 26, 2025

Mar a del Carmen Bonilla Rodr guez Deputy Undersecretary for Public Credit United Mexican States Insurgentes Sur 1971 Torre III, Piso 7 Colonia Guadalupe Inn M xico, Ciudad de M xico 01020

We have reviewed your draft registration statement and have the following comments.

Please respond to this letter by providing the requested information and publicly filing your registration statement and non-public draft submission on EDGAR. If you do not believe a comment applies to your facts and circumstances or do not believe an amendment is appropriate, please tell us why in your response.

After reviewing the information you provide in response to this letter and your filed registration statement, we may have additional comments. Unless we note otherwise, any references to prior comments are to comments in our August 6, 2025 letter.

Draft Registration Statement under Schedule B submitted July 11, 2025 Form 18-K/A filed August 19, 2025 Exhibit 99.1 Certain Financing and Support Transactions, page 1

1. Please disclose whether Mexico or PEMEX have any affiliation with EFL I through share ownership or management of EFL I. In this regard, please clarify how the Mexican Government executed the offering of pre-capitalized securities issued by August 26, 2025 Page 2

Eagle Funding. 2. We note your response to comment 11 of our letter dated August 6, 2025 and we reissue in part our prior comment. Please disclose whether the P-Caps are redeemable at the option of a holder of a P-Cap. In addition, please describe the class of persons to whom the P-Caps were sold to the extent practicable. 3. We note your response to comment 15 in our prior letter. To the extent that PEMEX were to be in breach under the repurchase transaction, please disclose any material effect on Mexico.

4. We note your disclosure that, The P-Caps issued by EFL I will not be consolidated with the liabilities of PEMEX or Mexico. Please advise us how these commitments by PEMEX and Mexico under the repurchase transactions or the facility agreement will be accounted for and disclosed in Mexico s future Form 18-K filings. General

5. We note your response to comment 16 in our letter dated August 6, 2025. In Mexico s Schedule B, to the extent known, please disclose if proceeds will be used to fund PEMEX, including the repurchase of its outstanding debt securities. 6. In Mexico s Schedule B, please include any material risk factors related to PEMEX s financial condition and operations to the extent such material factors present a risk to an investment in Mexico s offering. Please contact Samuel Kluck at 202-551-3233 or Michael Coco at 202-551-3253 with any other questions.

Sincerely,
Division of
Corporation Finance
Office of
International Corporate
Finance
cc: Jorge U. Juantorena

Show Raw Text
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<TEXT>
 August 26, 2025

Mar a del Carmen Bonilla Rodr guez
Deputy Undersecretary for Public Credit
United Mexican States
Insurgentes Sur 1971
Torre III, Piso 7
Colonia Guadalupe Inn
M xico, Ciudad de M xico 01020

 Re: United Mexican States
 Draft Registration Statement under Schedule B
 Submitted July 11, 2025
 CIK No. 0000101368
 _
 Form 18-K for fiscal year ended December 31, 2024
 Filed June 20, 2025, amended July 2, 2025, July 22, 2025 and August
19, 2025
 File No. 333-03610
Dear Mar a del Carmen Bonilla Rodr guez:

 We have reviewed your draft registration statement and have the
following comments.

 Please respond to this letter by providing the requested information and
publicly filing
your registration statement and non-public draft submission on EDGAR. If you do
not
believe a comment applies to your facts and circumstances or do not believe an
amendment is
appropriate, please tell us why in your response.

 After reviewing the information you provide in response to this letter
and your filed
registration statement, we may have additional comments. Unless we note
otherwise, any
references to prior comments are to comments in our August 6, 2025 letter.

Draft Registration Statement under Schedule B submitted July 11, 2025
Form 18-K/A filed August 19, 2025
Exhibit 99.1
Certain Financing and Support Transactions, page 1

1. Please disclose whether Mexico or PEMEX have any affiliation with EFL I
through
 share ownership or management of EFL I. In this regard, please clarify
how the
 Mexican Government executed the offering of pre-capitalized securities
issued by
 August 26, 2025
Page 2

 Eagle Funding.
2. We note your response to comment 11 of our letter dated August 6, 2025
and we
 reissue in part our prior comment. Please disclose whether the P-Caps are
redeemable
 at the option of a holder of a P-Cap. In addition, please describe the
class of persons to
 whom the P-Caps were sold to the extent practicable.
3. We note your response to comment 15 in our prior letter. To the extent
that PEMEX
 were to be in breach under the repurchase transaction, please disclose
any material
 effect on Mexico.

4. We note your disclosure that, The P-Caps issued by EFL I will not be
consolidated
 with the liabilities of PEMEX or Mexico. Please advise us how these
commitments
 by PEMEX and Mexico under the repurchase transactions or the facility
agreement
 will be accounted for and disclosed in Mexico s future Form 18-K
filings.
General

5. We note your response to comment 16 in our letter dated August 6, 2025.
In Mexico s
 Schedule B, to the extent known, please disclose if proceeds will be used
to fund
 PEMEX, including the repurchase of its outstanding debt securities.
6. In Mexico s Schedule B, please include any material risk factors
related to PEMEX s
 financial condition and operations to the extent such material factors
present a risk to
 an investment in Mexico s offering.
 Please contact Samuel Kluck at 202-551-3233 or Michael Coco at
202-551-3253 with
any other questions.

 Sincerely,

 Division of
Corporation Finance
 Office of
International Corporate
 Finance
cc: Jorge U. Juantorena
</TEXT>
</DOCUMENT>