SEC Company Response from REPUBLIC OF TURKEY (CIK 0000869687) — Apr 29, 2020
REPUBLIC OF TURKEY (CIK 0000869687)
Date: April 29, 2020 · CIK: 0000869687 · Accession: 0001193125-20-126241
AI Filing Summary & Sentiment
File numbers found in text: 333-236683
Referenced dates: April 24, 2020
Letter
VIA EDGAR AND E-MAIL United States Securities and Exchange Commission Division of Corporation Finance Office of International Corporate Finance Attention: Mr. Michael Coco, Chief Form 18-K for Fiscal Year Ended December 31, 2018 Filed September 26, 2019 Amended November 14, 2019, February 13, 2020 and April 10, 2020 File No. 033-37817
Dear Mr. Coco:
On behalf of the Republic of Turkey (the “Republic”), we are responding to the letter of the Staff of the Division of Corporation Finance (the “Staff”), dated April 24, 2020, regarding the above-referenced Registration Statement under Schedule B (the “Registration Statement”) and Annual Report on Form 18-K for the fiscal year ended December 31, 2018, as amended (the “Form 18-K”) of the Republic.
The Republic’s (1) Registration Statement has been revised in accordance with the Staff’s comments and is being filed simultaneously herewith, as part of an Amendment to the Republic’s Registration Statement (the “Amended Registration Statement”) and (2) Exhibit D to the Form 18-K has been revised in accordance with the Staff’s comments and is being filed simultaneously herewith, as part of an Amendment to the Form 18-K (the “Amended Form 18-K”).
For ease of reference, the Staff’s comments are reproduced below in bold italics, followed by the Republic’s responses.
Arnold & Porter Kaye Scholer LLP
250 West 55th Street | New York, NY 10019-9710 | www.arnoldporter.com
Mr. Michael Coco
April 29, 2020
Page 2
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.
The Republic has revised its disclosure in accordance with the Staff’s comment. Please see page 12 of Exhibit D-4 to the Amended Form 18-K.
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.
The Republic has revised its disclosure in accordance with the Staff’s comment. Please see page 33 of Exhibit D-4 to the Amended Form 18-K.
* * * * *
Should you or any member of the Staff have any questions concerning the enclosed materials or desire further information or clarification in connection therewith, please contact the undersigned at (212) 836-8861 or Christopher.Peterson@arnoldporter.com.
Very truly yours,
/s/ Christopher P. Peterson
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CORRESP 1 filename1.htm CORRESP April 29, 2020 VIA EDGAR AND E-MAIL United States Securities and Exchange Commission Division of Corporation Finance Office of International Corporate Finance 100 F Street, NE Washington, D.C. 20549-3628 Attention: Mr. Michael Coco, Chief 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, 2018 Filed September 26, 2019 Amended November 14, 2019, February 13, 2020 and April 10, 2020 File No. 033-37817 Dear Mr. Coco: On behalf of the Republic of Turkey (the “Republic”), we are responding to the letter of the Staff of the Division of Corporation Finance (the “Staff”), dated April 24, 2020, regarding the above-referenced Registration Statement under Schedule B (the “Registration Statement”) and Annual Report on Form 18-K for the fiscal year ended December 31, 2018, as amended (the “Form 18-K”) of the Republic. The Republic’s (1) Registration Statement has been revised in accordance with the Staff’s comments and is being filed simultaneously herewith, as part of an Amendment to the Republic’s Registration Statement (the “Amended Registration Statement”) and (2) Exhibit D to the Form 18-K has been revised in accordance with the Staff’s comments and is being filed simultaneously herewith, as part of an Amendment to the Form 18-K (the “Amended Form 18-K”). For ease of reference, the Staff’s comments are reproduced below in bold italics, followed by the Republic’s responses. Arnold & Porter Kaye Scholer LLP 250 West 55th Street | New York, NY 10019-9710 | www.arnoldporter.com Mr. Michael Coco April 29, 2020 Page 2 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. The Republic has revised its disclosure in accordance with the Staff’s comment. Please see page 12 of Exhibit D-4 to the Amended Form 18-K. 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. The Republic has revised its disclosure in accordance with the Staff’s comment. Please see page 33 of Exhibit D-4 to the Amended Form 18-K. * * * * * Should you or any member of the Staff have any questions concerning the enclosed materials or desire further information or clarification in connection therewith, please contact the undersigned at (212) 836-8861 or Christopher.Peterson@arnoldporter.com. Very truly yours, /s/ Christopher P. Peterson Christopher P. Peterson Arnold & Porter Kaye Scholer LLP cc: Yavuz ALKAN, Ministry of Treasury and Finance, Republic of Turkey Eren YAVUZ, Ministry of Treasury and Finance, Republic of Turkey