SEC Comment Letter 0000000000-24-003739 to REPUBLIC OF TURKEY (CIK 0000869687)
REPUBLIC OF TURKEY (CIK 0000869687)
Date: April 8, 2024 · CIK: 0000869687 · Accession: 0000000000-24-003739
AI Filing Summary & Sentiment
Letter
United States securities and exchange commission logo April 8, 2024 Zeynep Boga Deputy Director General Republic of Turkey Turkish Consulate General Office of the Attache for Treasury and Financial Affairs 821 First Avenue, 4th Floor New York, N.Y. 10017 Re:Republic of Turkey Amended Registration Statement under Schedule B Filed April 1, 2024 File No. 333-275976color:white;"_ Form 18-K/A for Fiscal Year Ended December 31, 2022 Filed September 22, 2023, as amended on February 15, 2024, March 21, 2024 and April 1, 2024 File No. 033-37817 Dear Zeynep Boga: We have reviewed your amended registration statement and have the following comments. 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. Unless we note otherwise, any references to prior comments are to comments in our January 5, 2024 letter. Amended Registration Statement under Schedule B Annual Report on Form 18-K/A, Exhibit 99.D Political Conditions, page 6 1.We note your response to our prior comment 5 and additional disclosure provided in the Recent Developments and Summary section of Exhibit D-3 to Form 18-K/A filed with the SEC on March 29, 2024. Please supplement your disclosure to account for the local
FirstName LastNameZeynep Boga Comapany NameRepublic of Turkey April 8, 2024 Page 2 FirstName LastName Zeynep Boga Republic of Turkey April 8, 2024 Page 2 elections that took place on March 31, 2024. Energy, page 97 2.We note your response to our prior comment 13 and supplemental explanatory information. Please revise your disclosure on page 97 to clarify that "energy resources" refers solely to crude oil and natural gas reserves. 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 Kelsey Glover at 202-551-2365 or Michael Coco at 202-551-3253 with any other questions. Sincerely, Division of Corporation Finance Office of International Corporate Finance
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United States securities and exchange commission logo
April 8, 2024
Zeynep Boga
Deputy Director General
Republic of Turkey
Turkish Consulate General
Office of the Attache for Treasury and Financial Affairs
821 First Avenue, 4th Floor
New York, N.Y. 10017
Re:Republic of Turkey
Amended Registration Statement under Schedule B
Filed April 1, 2024
File No. 333-275976color:white;"_
Form 18-K/A for Fiscal Year Ended December 31, 2022
Filed September 22, 2023, as amended on February 15, 2024, March 21, 2024
and April 1, 2024
File No. 033-37817
Dear Zeynep Boga:
We have reviewed your amended registration statement and have the following
comments.
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. Unless we note otherwise,
any references to prior comments are to comments in our January 5, 2024 letter.
Amended Registration Statement under Schedule B
Annual Report on Form 18-K/A, Exhibit 99.D
Political Conditions, page 6
1.We note your response to our prior comment 5 and additional disclosure provided in the
Recent Developments and Summary section of Exhibit D-3 to Form 18-K/A filed with the
SEC on March 29, 2024. Please supplement your disclosure to account for the local
FirstName LastNameZeynep Boga
Comapany NameRepublic of Turkey
April 8, 2024 Page 2
FirstName LastName
Zeynep Boga
Republic of Turkey
April 8, 2024
Page 2
elections that took place on March 31, 2024.
Energy, page 97
2.We note your response to our prior comment 13 and supplemental explanatory
information. Please revise your disclosure on page 97 to clarify that "energy resources"
refers solely to crude oil and natural gas reserves.
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 Kelsey Glover at 202-551-2365 or Michael Coco at 202-551-3253 with
any other questions.
Sincerely,
Division of Corporation Finance
Office of International Corporate
Finance