SEC Comment Letter for FIAT S P A (CIK 0000842317) — Jan 18, 2005
FIAT S P A (CIK 0000842317)
Date: Jan. 18, 2005 · CIK: 0000842317 · Accession: 0000000000-05-002916
AI Filing Summary & Sentiment
Letter
UNITED STATES SECURITIES AND EXCHANGE COMMISSION WASHINGTON, D.C. 20549-0404 DIVISION OF CORPORATION FINANCE Mail Stop 05-07 December 28, 2004 Via U.S. Mail Sergio Marchionne Chief Executive Officer Fiat S.p.A. Via Nizza 250, Turin, Italy
RE: Fiat S.p.A. Form 20-F for the year ended December 31, 2003 File No. 1-10108
Dear Mr. Marchionne:
We have limited our review of your Form 20-F to disclosures relating to your contacts with countries that have been identified as state sponsors of terrorism, and will make no further review of the Form 20-F. Our review with respect to this issue does not preclude further review by the Assistant Director group with respect to other issues. At this juncture, we are asking you to provide us with supplemental information, so that we may better understand your disclosure. Please be as detailed as necessary in your response. After reviewing this information, we may or may not raise Additional comments.
Please understand that the purpose of our review process is To assist you in your compliance with the applicable disclosure requirements and to enhance the overall disclosure in your filings. We look forward to working with you in these respects. We welcome any questions you may have about our comments or on any other aspect of our review. Feel free to call us at the telephone numbers listed at the end of this letter.
Form 20-F for the year ended December 31, 2003
General - We note the disclosure on p. B-12 of Exhibit 8.1 that the Company Has an Iranian subsidiary (Iran Magirus-Deutz), and the disclosure on p. B-17 that the Company has an interest in a Libyan company (Trucks & Bus Company). In light of the fact that these countries are identified by the U.S. State Department as states sponsor of terrorism, and Iran is subject to economic sanctions administered by the U.S. Treasury Department`s Office of Foreign Assets Control, please advise us of the materiality to the Company of its interests in these companies, and give us your view as to whether those interests constitute a material investment risk for your security holders. In preparing your response, please consider that evaluations of materiality should not be based solely on quantitative factors, but should include consideration of all factors that a reasonable investor would deem important in making an investment decision.
Closing
Please understand that we may have additional comments after We review your response to our comment. You may contact me at (202)942-7817 if you have any questions about the comment or our review.
Sincerely,
Cecilia Blye, Chief
Office of Global Security
Risk
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UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-0404
DIVISION OF
CORPORATION FINANCE
Mail Stop 05-07
December 28, 2004
Via U.S. Mail
Sergio Marchionne
Chief Executive Officer
Fiat S.p.A.
Via Nizza 250, Turin, Italy
RE: Fiat S.p.A.
Form 20-F for the year ended December 31, 2003
File No. 1-10108
Dear Mr. Marchionne:
We have limited our review of your Form 20-F to disclosures
relating to your contacts with countries that have been identified
as state sponsors of terrorism, and will make no further review of
the Form 20-F. Our review with respect to this issue does not
preclude further review by the Assistant Director group with respect to
other issues. At this juncture, we are asking you to provide us with
supplemental information, so that we may better understand your
disclosure. Please be as detailed as necessary in your response.
After reviewing this information, we may or may not raise
Additional comments.
Please understand that the purpose of our review process is
To assist you in your compliance with the applicable disclosure
requirements and to enhance the overall disclosure in your
filings. We look forward to working with you in these respects. We welcome
any questions you may have about our comments or on any other
aspect of our review. Feel free to call us at the telephone numbers
listed at the end of this letter.
Form 20-F for the year ended December 31, 2003
General -
We note the disclosure on p. B-12 of Exhibit 8.1 that the Company
Has an Iranian subsidiary (Iran Magirus-Deutz), and the disclosure on
p. B-17 that the Company has an interest in a Libyan company (Trucks
& Bus Company). In light of the fact that these countries are
identified by the U.S. State Department as states sponsor of
terrorism, and Iran is subject to economic sanctions administered
by the U.S. Treasury Department`s Office of Foreign Assets Control,
please advise us of the materiality to the Company of its
interests in these companies, and give us your view as to whether those
interests constitute a material investment risk for your security
holders. In preparing your response, please consider that
evaluations of materiality should not be based solely on
quantitative factors, but should include consideration of all factors that a
reasonable investor would deem important in making an investment
decision.
Closing
Please understand that we may have additional comments after
We review your response to our comment. You may contact me at
(202)942-7817 if you have any questions about the comment or our review.
Sincerely,
Cecilia Blye, Chief
Office of Global Security
Risk
cc: Max Webb
Assistant Director
Division of Corporation Finance
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