SEC Comment Letter for Banco Santander, S.A. (SAN, BCDRF) (CIK 0000891478) (SAN) — May 31, 2007
Banco Santander, S.A. (SAN, BCDRF) (CIK 0000891478)
Date: May 31, 2007 · CIK: 0000891478 · Accession: 0000000000-07-026935
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 001-12518
Letter
May 31, 2007 By U.S. Mail and facsimile to 011-34-91- 257-1282. José Antonio Alvarez 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 File No. 001-12518
Dear Mr. Alvarez:
We have reviewed your response and have the following additional comments. In our comments, we ask you to provide us with supplemental information so we may better understand your disclosure. After reviewing th is information, we may or may not raise additional comments. We may also have additional comments due to ongoing consultations with the Office of the Chie f Accountant of the Commission and with international accounting regulatory agencies.
Please understand that the purpose of our re view process is to assist you in your compliance with the applicable disclosure requirements and to enhance the overall disclosure in your filing. We look forward to working with you in these respects. We welcome any questions you may have about our comments or any other aspect of our review. Feel free to call us at the telephone numbers listed at the end of this letter.
Consolidated Financial Statements
58.3 Net Income and Stockholder’s Equity reconciliations between IFRS and U.S. GAAP, page F-122
1. We note that the Bank of Spain requir es specific application of minimum allowance percentages for non-performing past due assets which do not appear to consider transaction or clie nt specific factors. Pleas e tell us how you considered
José Antonio Alvarez May 31, 2007 Page 2 the application of these minimum allowa nce percentages in your IFRS to U.S. GAAP reconciliations.
2. Please tell us if you expect to record any difference in the allowance for loan losses under IFRS as a result of changing from the statistical provisioning model presently required by the Bank of Spain to the use of your internal risk models subsequent to approval by the Bank of Spain.
* * * * *
Please provide a response to these comment s within 10 business days or tell us when you will provide us with a response. Please furnish a cover letter that keys your response to our comments and provides the requested supplemental information. Please understand that we may have additional comments after reviewing your responses to our comments.
You may contact Rebekah M oore at (202) 551-3463 or me at (202) 551-3851 if you have questions.
Sincerely,
Paul Cline
Senior Accountant
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Mail Stop 4561 May 31, 2007 By U.S. Mail and facsimile to 011-34-91- 257-1282. José Antonio Alvarez 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 File No. 001-12518 Dear Mr. Alvarez: We have reviewed your response and have the following additional comments. In our comments, we ask you to provide us with supplemental information so we may better understand your disclosure. After reviewing th is information, we may or may not raise additional comments. We may also have additional comments due to ongoing consultations with the Office of the Chie f Accountant of the Commission and with international accounting regulatory agencies. Please understand that the purpose of our re view process is to assist you in your compliance with the applicable disclosure requirements and to enhance the overall disclosure in your filing. We look forward to working with you in these respects. We welcome any questions you may have about our comments or any other aspect of our review. Feel free to call us at the telephone numbers listed at the end of this letter. Consolidated Financial Statements 58.3 Net Income and Stockholder’s Equity reconciliations between IFRS and U.S. GAAP, page F-122 1. We note that the Bank of Spain requir es specific application of minimum allowance percentages for non-performing past due assets which do not appear to consider transaction or clie nt specific factors. Pleas e tell us how you considered José Antonio Alvarez May 31, 2007 Page 2 the application of these minimum allowa nce percentages in your IFRS to U.S. GAAP reconciliations. 2. Please tell us if you expect to record any difference in the allowance for loan losses under IFRS as a result of changing from the statistical provisioning model presently required by the Bank of Spain to the use of your internal risk models subsequent to approval by the Bank of Spain. * * * * * Please provide a response to these comment s within 10 business days or tell us when you will provide us with a response. Please furnish a cover letter that keys your response to our comments and provides the requested supplemental information. Please understand that we may have additional comments after reviewing your responses to our comments. You may contact Rebekah M oore at (202) 551-3463 or me at (202) 551-3851 if you have questions. Sincerely, Paul Cline Senior Accountant