Correspondence 0001193125-24-097065 from REPUBLIC OF TURKEY (CIK 0000869687)
REPUBLIC OF TURKEY (CIK 0000869687)
Date: April 16, 2024 · CIK: 0000869687 · Accession: 0001193125-24-097065
AI Filing Summary & Sentiment
File numbers found in text: 333-275976
Referenced dates: April 8, 2024
Letter
VIA EDGAR AND E-MAIL United States Securities and Exchange Commission Division of Corporation Finance Office of International Corporate Finance Attention: Ms. Kelsey Glover; Mr. Michael Coco Form 18-K for Fiscal Year Ended December 31, 2022 Filed September 22, 2023 Amended February 15, 2024, March 21, 2024 and March 29, 2024 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 8, 2024, 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, 2022, as amended (the “Form 18-K”) of the Republic.
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.
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 elections that took place on March 31, 2024.
Arnold & Porter Kaye Scholer LLP
250 West 55th Street | New York, NY 10019-9710 | www.arnoldporter.com
Ms. Kelsey Glover; Mr. Michael Coco
April 16, 2024
Page 2
The Republic has revised its disclosure in accordance with the Staff’s comment. Please see page 4 of Exhibit D-4 to the Amended Form 18-K.
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.
The Republic has revised its disclosure in accordance with the Staff’s comment. Please see page 97 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
Show Raw Text
CORRESP 1 filename1.htm CORRESP April 16, 2024 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: Ms. Kelsey Glover; Mr. Michael Coco Re: Republic of Turkey Registration Statement under Schedule B Filed December 11, 2023 Amended April 1, 2024 File No. 333-275976 Form 18-K for Fiscal Year Ended December 31, 2022 Filed September 22, 2023 Amended February 15, 2024, March 21, 2024 and March 29, 2024 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 8, 2024, 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, 2022, as amended (the “Form 18-K”) of the Republic. 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. 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 elections that took place on March 31, 2024. Arnold & Porter Kaye Scholer LLP 250 West 55th Street | New York, NY 10019-9710 | www.arnoldporter.com Ms. Kelsey Glover; Mr. Michael Coco April 16, 2024 Page 2 The Republic has revised its disclosure in accordance with the Staff’s comment. Please see page 4 of Exhibit D-4 to the Amended Form 18-K. 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. The Republic has revised its disclosure in accordance with the Staff’s comment. Please see page 97 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: Yiğit Korkmaz YAŞAR, Ministry of Treasury and Finance, Republic of Turkey Zeynep BOGA, Ministry of Treasury and Finance, Republic of Turkey