SEC Comment Letter 0000000000-23-013326 to QUEBEC (CIK 0000722803)
QUEBEC (CIK 0000722803)
Date: Dec. 6, 2023 · CIK: 0000722803 · Accession: 0000000000-23-013326
AI Filing Summary & Sentiment
Referenced dates: November 7, 2023
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United States securities and exchange commission logo
December 6, 2023
Martine Hébert
Déléguée générale du Québec à New York
Québec
One Rockefeller Plaza — 26th Floor
New York, New York 10020-2102
Re:Québec
Registration Statement under Schedule B
Filed October 12, 2023
File No. 333-274949color:white;"_
Form 18-K for Fiscal Year Ended March 31, 2023
Filed May 15, 2023, as amended on May 30, 2023, July 5, 2023, September 8,
2023, October 3, 2023, and November 13, 2023.
File No. 002-86339
Dear Martine Hébert:
We have reviewed your registration statement and have the following comment(s).
Please respond to this letter by amending your registration statement and providing the
requested information. 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 any amendment to your registration statement and the information you
provide in response to this letter, we may have additional comments.
Registration Statement under Schedule B
General
1.We note your response to comment 2 of our letter dated November 7, 2023. Please
incorporate your Report on Form 18-K/A, filed with the SEC on November 13, 2023, into
the Registration Statement under information incorporated by reference.
Annual Report on Form 18-K
Consolidated Financial Transactions, page 26
2.We note your response to our prior comment 7 and we reissue our comment. We note a
significant net decrease in cash between 2022 and preliminary 2023 in Table 10. Please
FirstName LastNameMartine Hébert
Comapany NameQuébec
December 6, 2023 Page 2
FirstName LastName
Martine Hébert
Québec
December 6, 2023
Page 2
revise your disclosure to either include the explanation in a footnote to the table or include
specific reference to where explanatory disclosure can be found.
Government Employees and Collective Unions, page 37
3.We note your response to our prior comment 10 and additional disclosure provided in
the Fall 2023 Economic and Financial Update on Form 18-K/A filed with the SEC on
November 13, 2023, providing the government’s fourth offer to the unions. Please revise
your disclosure to describe recent developments, including strikes by the unions in
November 2023 and announced strikes in December 2023, to the extent material.
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 Kateryna Kuntsevich at 202-320-3189 or Michael Coco at 202-551-3253
with any other questions.
Sincerely,
Division of Corporation Finance
Office of International Corporate
Finance