SEC Comment Letter for Banco Santander, S.A. (SAN, BCDRF) (CIK 0000891478) (SAN) — Apr 5, 2011
Banco Santander, S.A. (SAN, BCDRF) (CIK 0000891478)
Date: April 5, 2011 · CIK: 0000891478 · Accession: 0000000000-11-020995
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 001-12518
Referenced dates: September 29, 2010
Letter
April 5, 2011 By U.S. Mail and facsimile to 011-34-91- 257-1282 José Antonio Alvarez Chief Financial Officer Banco Santander, S.A. Ciudad Grupo Santander 28660 Boadilla del Monte Madrid, Spain Re: Banco Santander, S.A. Form 20-F for the Fiscal Year Ended December 31, 2009 File No. 001-12518
Dear Mr. Alvarez: We have reviewed your supplemental response and have the following comments. In some of our comments, we may ask you to provi de us with information so we may better understand your disclosure. Please respond to this letter within te n business days by providing the requested information, including a draft of your proposed disclosures to be ma de in future filings clearly identifying new and deleted disclosure, or by advising us when you will provide the requested response. If you do not believe our comments apply to your fact s and circumstances or do not believe future revisions are appropriate, please tell us why in your response. After reviewing the information you provide in response to these comments, including the draft of your proposed disclosures, we may have additional comments. Form 20-F for the fiscal year ended December 31, 2009
General
1. We note your response to prior comment 3 of our letter dated September 29, 2010. Please expand your qualitative materiality anal ysis to address your continuing business relationships with entities that are include d in the U.S. Department of the Treasury’s Office of Foreign Assets Cont rol’s Specially Designated Nationals List, such as Bank Sepah, Bank Mellat, and Banco Nacional de Cuba.
José Antonio Alvarez Banco Santander, S.A. April 5, 2011 Page 2
Note 7. Debt Instruments, page F-79
2. We note your response and proposed disclosure to prior comment 16 of our letter dated September 29, 2010. Given the significance of gross unrealized losses on equity securities to the related equ ity securities’ fair value at December 31, 2009, please tell us and revise future filings to di sclose total gross unrealized lo sses on securities segregated between those losses incurred for 12-months or less and those incurred for 12-months or more. Further, if any of your equity securi ties have been underwa ter for greater than 12- months, please tell us and fu rther expand your proposed disclosure to address in more detail how you were able to concluded that no impairment was necessary at period end. Please specifically address how you consider ed paragraph 61 of IAS 39 in your other- than-temporary impairment analysis for underwater equity securities.
You may contact Brittany Ebbertt, Staff Accountant at (202) 551- 3572 or me at (202) 551-3494 with any other questions. Sincerely,
Kevin W. Vaughn Accounting Branch Chief
Show Raw Text
April 5, 2011
By U.S. Mail and facsimile to 011-34-91- 257-1282
José Antonio Alvarez Chief Financial Officer Banco Santander, S.A. Ciudad Grupo Santander 28660 Boadilla del Monte Madrid, Spain
Re: Banco Santander, S.A.
Form 20-F for the Fiscal Year Ended December 31, 2009
File No. 001-12518
Dear Mr. Alvarez:
We have reviewed your supplemental response and have the following comments. In
some of our comments, we may ask you to provi de us with information so we may better
understand your disclosure.
Please respond to this letter within te n business days by providing the requested
information, including a draft of your proposed disclosures to be ma de in future filings clearly
identifying new and deleted disclosure, or by advising us when you will provide the requested
response. If you do not believe our comments apply to your fact s and circumstances or do not
believe future revisions are appropriate, please tell us why in your response.
After reviewing the information you provide in response to these comments, including
the draft of your proposed disclosures, we may have additional comments.
Form 20-F for the fiscal year ended December 31, 2009
General
1. We note your response to prior comment 3 of our letter dated September 29, 2010.
Please expand your qualitative materiality anal ysis to address your continuing business
relationships with entities that are include d in the U.S. Department of the Treasury’s
Office of Foreign Assets Cont rol’s Specially Designated Nationals List, such as Bank
Sepah, Bank Mellat, and Banco Nacional de Cuba.
José Antonio Alvarez Banco Santander, S.A. April 5, 2011 Page 2
Note 7. Debt Instruments, page F-79
2. We note your response and proposed disclosure to prior comment 16 of our letter dated
September 29, 2010. Given the significance of gross unrealized losses on equity
securities to the related equ ity securities’ fair value at December 31, 2009, please tell us
and revise future filings to di sclose total gross unrealized lo sses on securities segregated
between those losses incurred for 12-months or less and those incurred for 12-months or
more. Further, if any of your equity securi ties have been underwa ter for greater than 12-
months, please tell us and fu rther expand your proposed disclosure to address in more
detail how you were able to concluded that no impairment was necessary at period end.
Please specifically address how you consider ed paragraph 61 of IAS 39 in your other-
than-temporary impairment analysis for underwater equity securities.
You may contact Brittany Ebbertt, Staff Accountant at (202) 551- 3572 or me at (202)
551-3494 with any other questions.
Sincerely,
Kevin W. Vaughn Accounting Branch Chief