SEC Comment Letter for Banco Santander, S.A. (SAN, BCDRF) (CIK 0000891478) (SAN) — Nov 16, 2006
Banco Santander, S.A. (SAN, BCDRF) (CIK 0000891478)
Date: Nov. 16, 2006 · CIK: 0000891478 · Accession: 0000000000-06-056630
AI Filing Summary & Sentiment
Reasoning
Referenced dates: September 25, 2006, September 25, 2006
Letter
November 16, 2006 Via U.S. Mail and Facsimile Alfredo Saenz Chief Financial Officer Banco Santander Central Hispano, S.A. Ciudad Grupo Santander 28660 Boadilla del Monte Madrid, Spain
RE: Banco Santander Central Hispano, S.A. Form 20-F for the fiscal year ended December 31, 2005 Response letter dated September 25, 2006 File No. 1-12518
Dear Mr. Saenz:
We have reviewed your response dated September 25, 2006, and have the following comments. Please be as detailed as necessary in your response. After reviewing this information, we may raise additional comments. 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.
General -
1. We note the representation in your response letter dated September 25, 2006, that you have correspondent relationships with Iranian banks, including Bank Saderat. Please expand your qualitative materiality analysis to address the fact that the United States Department of the Treasury has recently identified Bank Saderat as facilitating Iran`s transfer of funds to terrorist organizations. Please also discuss any measures you have in place to stem terrorism financing, and their impact on your Iran-related operations. 2. Please address the applicability to your Iran-related operations of Section 5(b) of the Iran and Libya Sanctions Act of 1996 (now the Iran Sanctions Act of 1996), as revised by the Iran Freedom Support Act, enacted on September 30, 2006.
Please respond to this comment within 10 business days or tell us when you will provide us with a response. Please file your response letter on EDGAR.
Please contact Jack Guggenheim at (202) 551-3523 if you have any questions about the comments or our review. You may also contact me at (202) 551-3470.
Sincerely,
Cecilia D. Blye, Chief
Office of Global Security
Risk
Show Raw Text
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<TYPE>LETTER
<SEQUENCE>1
<FILENAME>filename1.txt
<TEXT>
November 16, 2006
Via U.S. Mail and Facsimile
Alfredo Saenz
Chief Financial Officer
Banco Santander Central Hispano, S.A.
Ciudad Grupo Santander
28660 Boadilla del Monte
Madrid, Spain
RE: Banco Santander Central Hispano, S.A.
Form 20-F for the fiscal year ended December 31, 2005
Response letter dated September 25, 2006
File No. 1-12518
Dear Mr. Saenz:
We have reviewed your response dated September 25, 2006, and
have the following comments. Please be as detailed as necessary
in
your response. After reviewing this information, we may raise
additional comments. 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.
General -
1. We note the representation in your response letter dated
September
25, 2006, that you have correspondent relationships with Iranian
banks, including Bank Saderat. Please expand your qualitative
materiality analysis to address the fact that the United States
Department of the Treasury has recently identified Bank Saderat as
facilitating Iran`s transfer of funds to terrorist organizations.
Please also discuss any measures you have in place to stem
terrorism
financing, and their impact on your Iran-related operations.
2. Please address the applicability to your Iran-related
operations
of Section 5(b) of the Iran and Libya Sanctions Act of 1996 (now
the
Iran Sanctions Act of 1996), as revised by the Iran Freedom
Support
Act, enacted on September 30, 2006.
Please respond to this comment within 10 business days or tell us
when you will provide us with a response. Please file your
response
letter on EDGAR.
Please contact Jack Guggenheim at (202) 551-3523 if you have
any questions about the comments or our review. You may also
contact
me at (202) 551-3470.
Sincerely,
Cecilia D. Blye, Chief
Office of Global Security
Risk
cc: Todd Schiffman
Donald Walker
Division of Corporation Finance
Nicholas Kronfeld
Davis Polk & Wardwell
Alfredo Saenz
Banco Santander Central Hispano, S.A.
November 16, 2006
Page 1
UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-5546
DIVISION OF
CORPORATION FINANCE
</TEXT>
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