SEC Comment Letter for REPUBLIC OF TURKEY (CIK 0000869687) — Apr 27, 2020
REPUBLIC OF TURKEY (CIK 0000869687)
Date: April 27, 2020 · CIK: 0000869687 · Accession: 0000000000-20-003553
AI Filing Summary & Sentiment
File numbers found in text: 333-236683
Letter
Via E -mail Onur Saylan Treasury and Financial Counselor Turkish Embassy Office of the Counselor for Treasury and Financial Affairs 2525 Massachusetts Avenue, N.W. Washington, D.C. 20008 Form 18 -K for Fiscal Year Ended December 31, 201 8 Filed September 26, 2019 Amended November 14, 2019 , February 13, 2020 and April 10, 2020 File No. 033-37817
Re: Republic of Turkey Registration Statement under Schedule B Filed February 27, 2020 Amended April 10, 2020 File No. 333-236683
Dear Mr. Saylan :
We have reviewed your filing s 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 your documents and providing the requested information. If yo u 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 amendment to your registration statement and the information you provide in response to these comments, we may have additional comments.
Amendment No. 3 to Form 18 -K Exhibit D -3 The European Union and the United Kingdom , page 10
1. We reissue our prior comment 9. Please specify the material conclusions of the 2018 report that you reference in your new disclosure and provide a balanced discussion of any material concerns raised in the 2019 report .
Onur Saylan April 24 , 2020 Page 2
Location, Area and Topography, page 32 2. We note your response to comment 4. To the extent practicable, please include a more detailed discussion your new disaster management strategy so prospective investors may understand how it may mitigate any risks or effects of natural disasters.
Closing Comment
We remind you that you are responsible for the accuracy and adequacy of the disclosures, notwithstanding any review, comments, action or absence of action by the staff.
Refer to Rules 460 and 461 regarding requests for acceleration. Pl ease allow adequate time for us to review any amendment prior to the requested effective date of the registration statement.
Please contact Corey Jennings, Special Counsel, at (202) 551 -3258 or Michael Coco, Chief, at (202) 551 -3253 with any question s.
Sincerely,
/s/ Michael Coco
Show Raw Text
April 24, 2020
Via E -mail
Onur Saylan
Treasury and Financial Counselor
Turkish Embassy
Office of the Counselor for Treasury and Financial Affairs
2525 Massachusetts Avenue, N.W.
Washington, D.C. 20008
Re: Republic of Turkey
Registration Statement under Schedule B
Filed February 27, 2020
Amended April 10, 2020
File No. 333-236683
Form 18 -K for Fiscal Year Ended December 31, 201 8
Filed September 26, 2019
Amended November 14, 2019 , February 13, 2020 and April 10, 2020
File No. 033-37817
Dear Mr. Saylan :
We have reviewed your filing s 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 your documents and providing the requested
information. If yo u 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 amendment to your registration statement and the information you
provide in response to these comments, we may have additional comments.
Amendment No. 3 to Form 18 -K
Exhibit D -3
The European Union and the United Kingdom , page 10
1. We reissue our prior comment 9. Please specify the material conclusions of the
2018 report that you reference in your new disclosure and provide a balanced
discussion of any material concerns raised in the 2019 report .
Onur Saylan
April 24 , 2020
Page 2
Location, Area and Topography, page 32
2. We note your response to comment 4. To the extent practicable, please include a
more detailed discussion your new disaster management strategy so prospective
investors may understand how it may mitigate any risks or effects of natural
disasters.
Closing Comment
We remind you that you are responsible for the accuracy and adequacy of the disclosures,
notwithstanding any review, comments, action or absence of action by the staff.
Refer to Rules 460 and 461 regarding requests for acceleration. Pl ease allow adequate
time for us to review any amendment prior to the requested effective date of the registration
statement.
Please contact Corey Jennings, Special Counsel, at (202) 551 -3258 or Michael Coco,
Chief, at (202) 551 -3253 with any question s.
Sincerely,
/s/ Michael Coco
Division of Corporation Finance
Office of International Corporate
Finance
cc: Christopher Peterson , Esq.
Arnold & Porter Kaye Scholer LLP