SEC Comment Letter for PROVINCE OF MANITOBA (CIK 0000826926) — Jan 31, 2020
PROVINCE OF MANITOBA (CIK 0000826926)
Date: Jan. 31, 2020 · CIK: 0000826926 · Accession: 0000000000-20-000921
AI Filing Summary & Sentiment
File numbers found in text: 333-19538, 333-235898
Letter
January 30, 2020 Via Email Bruce Gray Acting Deputy Minister of Finance Province of Manitoba Department of Finance Room 109, Legislative Building 450 Broadway Winnipeg, Manitoba, Canada R3C 0V8 Form 18 -K for Fiscal Year Ended March 31, 2019 , as amended Filed November 7 , 2019 as amended December 16, 2019 File No. 333-19538
Re: Province of Manitoba Registration Statement under Schedule B Filed January 13, 2020 File No. 333-235898
Dear M r. Gray :
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 yo ur 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 amendmen t to your registration statement and the information you provide in response to these comments, we may have additional comments.
Registration Statement under Schedule B
General
1. To the extent possible, please update all statistics and information in the registration statement and the Form 18 -K to provide the most recent data.
Bruce Gray Province of Manitoba January 30, 2020 Page 2
Form 18 -K/A for Fiscal Year Ended March 31, 2019
2. We note that the Province filed a fiscal and economic update on December 16, 2019 and included statement s explaining an increase in revenue forecast and decrease in expense forecast. We further note the disclosure that this mid -year fiscal update does not present departmental results and that such information will be included in your next fiscal update . The Form 18 -K/A is incorporated by reference into the registration statement, and thus, it is unclear such statements are fully supported. Please advise.
Refer to Rules 460 and 461 regarding requests for acceleration. Please allow adequate time for us to r eview any amendment prior to the requested effective date of the registration statement.
Please contact Thomas Kluck , Special Counsel, at (202) 551 -3233 or Michael Coco, Chief, at (202) 551 -3253 with any questions .
Sincerely,
/s/ Michael Coco
Show Raw Text
January 30, 2020
Via Email
Bruce Gray
Acting Deputy Minister of Finance
Province of Manitoba
Department of Finance
Room 109, Legislative Building
450 Broadway
Winnipeg, Manitoba, Canada
R3C 0V8
Re: Province of Manitoba
Registration Statement under Schedule B
Filed January 13, 2020
File No. 333-235898
Form 18 -K for Fiscal Year Ended March 31, 2019 , as amended
Filed November 7 , 2019 as amended December 16, 2019
File No. 333-19538
Dear M r. Gray :
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 yo ur 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 amendmen t to your registration statement and the information you
provide in response to these comments, we may have additional comments.
Registration Statement under Schedule B
General
1. To the extent possible, please update all statistics and information in the registration
statement and the Form 18 -K to provide the most recent data.
Bruce Gray
Province of Manitoba
January 30, 2020
Page 2
Form 18 -K/A for Fiscal Year Ended March 31, 2019
2. We note that the Province filed a fiscal and economic update on December 16, 2019 and
included statement s explaining an increase in revenue forecast and decrease in expense
forecast. We further note the disclosure that this mid -year fiscal update does not present
departmental results and that such information will be included in your next fiscal update .
The Form 18 -K/A is incorporated by reference into the registration statement, and thus, it
is unclear such statements are fully supported. Please advise.
Refer to Rules 460 and 461 regarding requests for acceleration. Please allow adequate
time for us to r eview any amendment prior to the requested effective date of the registration
statement.
Please contact Thomas Kluck , Special Counsel, at (202) 551 -3233 or Michael Coco,
Chief, at (202) 551 -3253 with any questions .
Sincerely,
/s/ Michael Coco
Division of Corporation Finance
Office of International Corporate
Finance
cc: Robert E. Buckholz Jr ., Esq.
Sullivan & Cromwell