SEC Comment Letter for Banco Santander, S.A. (SAN, BCDRF) (CIK 0000891478) (SAN) — Mar 21, 2007
Banco Santander, S.A. (SAN, BCDRF) (CIK 0000891478)
Date: March 21, 2007 · CIK: 0000891478 · Accession: 0000000000-07-014538
AI Filing Summary & Sentiment
Reasoning
Referenced dates: December 20, 2006, December 1, 2006, February 2, 2007, February 2, 2007, September 25, 2006
Letter
March 21, 2007 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 Response letter dated December 1, 2006 Response letter dated February 2, 2007 File No. 1-12518
Dear Mr. Saenz:
We have reviewed your response letter dated February 2, 2007, 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 your response to comment 1 of our letter dated December 20, 2006. We remain of the view that it would be appropriate for future filings to include disclosure regarding your Iran-related operations, including the fact that you maintain a correspondent relationship with Bank Saderat and the fact that the U.S. Department of the Treasury has identified Bank Saderat as facilitating Iran`s transfer of funds to terrorist organizations. The disclosure should also include the fact that you maintain a correspondent relationship with Bank Sepah and the fact that the U.S. Department of the Treasury has designated Bank Sepah for providing support and services to designated Iranian proliferation firms. 2. We note your response to comment 2 of our letter dated December 20, 2006. It appears to the staff that it would be appropriate for future filings to include disclosure regarding the fact that you maintain a correspondent relationship with the Commercial Bank of Syria and that the U.S. Department of the Treasury has designated the Commercial Bank of Syria as a bank of primary money laundering concern. 3. Please provide us with the text of the disclosure you propose to include in response to the foregoing comments prior to including it in a filed document.
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 comment 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
<DOCUMENT>
<TYPE>LETTER
<SEQUENCE>1
<FILENAME>filename1.txt
<TEXT>
March 21, 2007
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
Response letter dated December 1, 2006
Response letter dated February 2, 2007
File No. 1-12518
Dear Mr. Saenz:
We have reviewed your response letter dated February 2,
2007,
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 your response to comment 1 of our letter dated December
20, 2006. We remain of the view that it would be appropriate for
future filings to include disclosure regarding your Iran-related
operations, including the fact that you maintain a correspondent
relationship with Bank Saderat and the fact that the U.S.
Department
of the Treasury has identified Bank Saderat as facilitating Iran`s
transfer of funds to terrorist organizations. The disclosure
should
also include the fact that you maintain a correspondent
relationship
with Bank Sepah and the fact that the U.S. Department of the
Treasury
has designated Bank Sepah for providing support and services to
designated Iranian proliferation firms.
2. We note your response to comment 2 of our letter dated December
20, 2006. It appears to the staff that it would be appropriate
for
future filings to include disclosure regarding the fact that you
maintain a correspondent relationship with the Commercial Bank of
Syria and that the U.S. Department of the Treasury has designated
the
Commercial Bank of Syria as a bank of primary money laundering
concern.
3. Please provide us with the text of the disclosure you propose
to
include in response to the foregoing comments prior to including
it
in a filed document.
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 comment 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.
March 21, 2007
Page 1
UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-5546
DIVISION OF
CORPORATION FINANCE
</TEXT>
</DOCUMENT>