SEC Comment Letter 0000000000-23-006745 to URUGUAY REPUBLIC OF (CIK 0000102385)
URUGUAY REPUBLIC OF (CIK 0000102385)
Date: June 23, 2023 · CIK: 0000102385 · Accession: 0000000000-23-006745
AI Filing Summary & Sentiment
File numbers found in text: 333-07128
Letter
United States securities and exchange commission logo June 23, 2023 Gabriela Tobias Counsel to the Ministry of Economy & Finance República Oriental del Uruguay Embassy of Uruguay 1913 I Street N.W., Lobby Washington, D.C. 20006 Ignacio Lagos Counsel Cleary Gottlieb Steen & Hamilton LLP One Liberty Plaza New York, NY 10006 Re:República Oriental del Uruguay Amendment No. 1 to Registration Statement under Schedule B Filed June 15, 2023 File No. 333-270970color:white;"_ Form 18-K for the year ended December 31, 2022 Filed June 15, 2023 File No. 333-07128 Dear Gabriela Tobias: We have reviewed your amended registration statement and have the following comment. Please respond to this letter by amending your filing and providing the requested information. If you do not believe our comment applies to your facts and circumstances or do not believe an amendment is appropriate, please tell us why in your response. After reviewing any amendment and the information you provide in response to this comment, we may have additional comments. Form 18-K, Filed June 15, 2023 Environmental, Social & Governance Matters Sovereign Sustainable Finance, page D-19 1.You state on page D-19 that “[t]he SSLB Framework…has been favorably evaluated by an independent ratings and analytics firm. Such firm has indicated in a report delivered to
FirstName LastNameGabriela Tobias Comapany NameRepública Oriental del Uruguay June 23, 2023 Page 2 FirstName LastName Gabriela Tobias República Oriental del Uruguay June 23, 2023 Page 2 Uruguay that the SSLB Framework is aligned with the International Capital Market Association's Sustainability-Linked Bond Principles published in June 2020.” Please file a consent pursuant to Rule 436 of the Securities Act for this firm or tell us why you believe you are not required to do so. In this regard, we note this report, available on Uruguay's Sovereign Sustainability-Linked Bonds webpage, may have been commissioned by you for use in connection with this registration statement as it states "[t]he Second-Party Opinion is valid for issuances aligned with the respective Framework for which the Second-Party Opinion was written" and page S-6 of your prospectus filed on October 24, 2022 also refers to this report.
Please contact Angie Kim, Special Counsel, at (202) 551-3535 or Michael Coco, Office Chief, at (202) 551-3253 with any questions. Sincerely, Division of Corporation Finance Office of International Corporate Finance
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United States securities and exchange commission logo
June 23, 2023
Gabriela Tobias
Counsel to the Ministry of Economy & Finance
República Oriental del Uruguay
Embassy of Uruguay
1913 I Street N.W., Lobby
Washington, D.C. 20006
Ignacio Lagos
Counsel
Cleary Gottlieb Steen & Hamilton LLP
One Liberty Plaza
New York, NY 10006
Re:República Oriental del Uruguay
Amendment No. 1 to Registration Statement under Schedule B
Filed June 15, 2023
File No. 333-270970color:white;"_
Form 18-K for the year ended December 31, 2022
Filed June 15, 2023
File No. 333-07128
Dear Gabriela Tobias:
We have reviewed your amended registration statement and have the following
comment. Please respond to this letter by amending your filing and providing the requested
information. If you do not believe our comment applies to your facts and circumstances or do
not believe an amendment is appropriate, please tell us why in your response.
After reviewing any amendment and the information you provide in response to this
comment, we may have additional comments.
Form 18-K, Filed June 15, 2023
Environmental, Social & Governance Matters
Sovereign Sustainable Finance, page D-19
1.You state on page D-19 that “[t]he SSLB Framework…has been favorably evaluated by
an independent ratings and analytics firm. Such firm has indicated in a report delivered to
FirstName LastNameGabriela Tobias
Comapany NameRepública Oriental del Uruguay
June 23, 2023 Page 2
FirstName LastName
Gabriela Tobias
República Oriental del Uruguay
June 23, 2023
Page 2
Uruguay that the SSLB Framework is aligned with the International Capital Market
Association's Sustainability-Linked Bond Principles published in June 2020.” Please file
a consent pursuant to Rule 436 of the Securities Act for this firm or tell us why you
believe you are not required to do so. In this regard, we note this report, available on
Uruguay's Sovereign Sustainability-Linked Bonds webpage, may have been
commissioned by you for use in connection with this registration statement as it states
"[t]he Second-Party Opinion is valid for issuances aligned with the respective Framework
for which the Second-Party Opinion was written" and page S-6 of your prospectus filed on
October 24, 2022 also refers to this report.
Please contact Angie Kim, Special Counsel, at (202) 551-3535 or Michael Coco, Office
Chief, at (202) 551-3253 with any questions.
Sincerely,
Division of Corporation Finance
Office of International Corporate
Finance