SEC Comment Letter for Banco Santander, S.A. (SAN, BCDRF) (CIK 0000891478) (SAN) — Nov 14, 2007
Banco Santander, S.A. (SAN, BCDRF) (CIK 0000891478)
Date: Nov. 14, 2007 · CIK: 0000891478 · Accession: 0000000000-07-055744
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 001-12518
Referenced dates: October 5, 2007
Letter
Re: Banco Santander Central Hispano, S.A. Form 20-F for the Fiscal Year Ended December 31, 2006 File No. 001-12518 Dear Mr. Alvarez:
Mail Stop 4561 October 22, 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
We have reviewed your response filed w ith the Commission October 18, 2007 and have the following additional comment. Where i ndicated, we think you should revise your document in response to this comment in future filings. If you disagree, we will consider your explanation as to why our comment is inapplicable or a revision is unnecessary. Please be as detailed as nece ssary in your explanation. In our comment, we may ask you to provide us with supplemental inform ation so we may better understand your disclosure. After reviewing this inform ation, we may or may not raise additional comments. We welcome any questions you ma y have about our comments or any other aspect of our review. Feel fr ee to call us at the telephone numbe rs listed at the end of this letter. Consolidated Financial Statements
Consolidated Financial Statements d) Measurement of financial a ssets and liabilities and recognition of fair value changes iii) Valuation tec hniques, page F-19
1. We note your response to prior comment tw o in our letter dated October 5, 2007. We continue to believe that additional disclosure should be provided to comply with the fair value disclosure requirements in IFRS 7. Specifically, we note the reference to various models and methodologi es used to determ ine fair value for
José Antonio Alvarez Banco Santander Central Hispano, S.A. October 22, 2007 Page 2 your financial instruments, including th e present value method, the Black-Scholes paradigm, the Heath-Jarrow-Morton mode l, and the standard Gaussian copula methodology. Please revise future fili ngs to include a discussion of the significant assumptions and inputs into each of these different models and methodologies as required by paragraph 27(a) of IFRS 7. For example, disclose the significant inputs into these mode ls that have the potential to most significantly impact the value determined, and the assumptions for those inputs for all periods presented.
* * * * *
Please revise your document in response to this comment within 10 business days or tell us when you will provide us with a response. Please provide us with your proposed disclosures and furnish a cover lette r that keys your response to our comment, indicates your intent to incl ude the requested revisions in your future filings and provides any requested supplemental information. Pleas e understand that we may have additional comments after reviewing your responses to our comment.
You may contact Rebekah M oore at (202) 551-3463 or me at (202) 551-3494 if you have questions.
Sincerely, Kevin W. Vaughn Branch Chief
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Mail Stop 4561 October 22, 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, 2006 File No. 001-12518 Dear Mr. Alvarez: We have reviewed your response filed w ith the Commission October 18, 2007 and have the following additional comment. Where i ndicated, we think you should revise your document in response to this comment in future filings. If you disagree, we will consider your explanation as to why our comment is inapplicable or a revision is unnecessary. Please be as detailed as nece ssary in your explanation. In our comment, we may ask you to provide us with supplemental inform ation so we may better understand your disclosure. After reviewing this inform ation, we may or may not raise additional comments. We welcome any questions you ma y have about our comments or any other aspect of our review. Feel fr ee to call us at the telephone numbe rs listed at the end of this letter. Consolidated Financial Statements Consolidated Financial Statements d) Measurement of financial a ssets and liabilities and recognition of fair value changes iii) Valuation tec hniques, page F-19 1. We note your response to prior comment tw o in our letter dated October 5, 2007. We continue to believe that additional disclosure should be provided to comply with the fair value disclosure requirements in IFRS 7. Specifically, we note the reference to various models and methodologi es used to determ ine fair value for José Antonio Alvarez Banco Santander Central Hispano, S.A. October 22, 2007 Page 2 your financial instruments, including th e present value method, the Black-Scholes paradigm, the Heath-Jarrow-Morton mode l, and the standard Gaussian copula methodology. Please revise future fili ngs to include a discussion of the significant assumptions and inputs into each of these different models and methodologies as required by paragraph 27(a) of IFRS 7. For example, disclose the significant inputs into these mode ls that have the potential to most significantly impact the value determined, and the assumptions for those inputs for all periods presented. * * * * * Please revise your document in response to this comment within 10 business days or tell us when you will provide us with a response. Please provide us with your proposed disclosures and furnish a cover lette r that keys your response to our comment, indicates your intent to incl ude the requested revisions in your future filings and provides any requested supplemental information. Pleas e understand that we may have additional comments after reviewing your responses to our comment. You may contact Rebekah M oore at (202) 551-3463 or me at (202) 551-3494 if you have questions. Sincerely, Kevin W. Vaughn Branch Chief