SEC Comment Letter for Banco BBVA Argentina S.A. (BBAR) (CIK 0000913059) (BBAR) — Jan 6, 2015
Banco BBVA Argentina S.A. (BBAR) (CIK 0000913059)
Date: Jan. 6, 2015 · CIK: 0000913059 · Accession: 0000000000-15-000741
AI Filing Summary & Sentiment
Reasoning
Referenced dates: September 30, 2014
Letter
January 6, 2015 Via E -mail Ignacio Sanz y Arcelus Chief Financial Officer BBVA Banco Franc és S.A. Reconquista 199 (C1003ABB) Buenos Aires. Republic of Argentina
Re: BBVA Banco Franc és S.A. Form 20-F for Fiscal Year Ended December 31, 2013 Filed April 21, 2014 Response dated October 31, 2014 File No. 1-12568
Dear Mr. Sanz y Arcelus :
We have reviewed your correspondence dated October 31, 2014, and we have the following additional comments.
Form 20 -F for Fiscal Year Ended December 31, 2013
Item 4. Information on the Company, page 14
Classification System According to Central Bank Regulations, page 58
1. We note your response to comment 2 in our letter dated September 30, 2014, regarding the term “RPC,” or “Total Regulatory Capital.” Please revise your disclosure in your next Form 20 -F to explain, including a tabular presentation, the calculation of your RPC as of relevant dates. Please explain any sign ificant variations between how RPC is calculated and the calculation of the capital measures which were displayed on page 90 of your Form 20 -F for the 2013 fiscal year.
Item 5. Operating and Financial Review and Prospects, page 106
2. We note your response to comment 4 in our letter dated September 30, 2014. In your next Form 20-F, please clarify the extent to which the negotiated salary increases to which you refer in your response are driven by unofficial inflation measures. Also clarify how often you ne gotiate salary increases.
Ignacio Sanz y Arcelus BBVA Banco Franc és S.A. January 6, 2015 Page 2
3. We note your response to comment 5 in our letter dated September 30, 2014. Given that the practice of indexation by a benchmark stabilization coefficient is unique to the context of banking in Argentina, please explain this co ncept further for the benefit of your U.S. investor audience. Explain why you engage in indexation to the CER. Also explain any risks or limitations of indexation to the CER, given that the Argentine Central Bank calculates the index based on variations in the Consumer Price Index, which has been subject to concerns regarding inaccuracy (as described on page 8 of your 2013 Form 20 -F). Please show us your proposed revised disclosure on a draft basis.
Please contact Alexandra M. Ledbetter, Staff Attorney, at (202) 551 -3317 or me a t (202) 551-3419 with any questions.
Sincerely,
/s/ Christian Windsor
Show Raw Text
January 6, 2015 Via E -mail Ignacio Sanz y Arcelus Chief Financial Officer BBVA Banco Franc és S.A. Reconquista 199 (C1003ABB) Buenos Aires. Republic of Argentina Re: BBVA Banco Franc és S.A. Form 20-F for Fiscal Year Ended December 31, 2013 Filed April 21, 2014 Response dated October 31, 2014 File No. 1-12568 Dear Mr. Sanz y Arcelus : We have reviewed your correspondence dated October 31, 2014, and we have the following additional comments. Form 20 -F for Fiscal Year Ended December 31, 2013 Item 4. Information on the Company, page 14 Classification System According to Central Bank Regulations, page 58 1. We note your response to comment 2 in our letter dated September 30, 2014, regarding the term “RPC,” or “Total Regulatory Capital.” Please revise your disclosure in your next Form 20 -F to explain, including a tabular presentation, the calculation of your RPC as of relevant dates. Please explain any sign ificant variations between how RPC is calculated and the calculation of the capital measures which were displayed on page 90 of your Form 20 -F for the 2013 fiscal year. Item 5. Operating and Financial Review and Prospects, page 106 2. We note your response to comment 4 in our letter dated September 30, 2014. In your next Form 20-F, please clarify the extent to which the negotiated salary increases to which you refer in your response are driven by unofficial inflation measures. Also clarify how often you ne gotiate salary increases. Ignacio Sanz y Arcelus BBVA Banco Franc és S.A. January 6, 2015 Page 2 3. We note your response to comment 5 in our letter dated September 30, 2014. Given that the practice of indexation by a benchmark stabilization coefficient is unique to the context of banking in Argentina, please explain this co ncept further for the benefit of your U.S. investor audience. Explain why you engage in indexation to the CER. Also explain any risks or limitations of indexation to the CER, given that the Argentine Central Bank calculates the index based on variations in the Consumer Price Index, which has been subject to concerns regarding inaccuracy (as described on page 8 of your 2013 Form 20 -F). Please show us your proposed revised disclosure on a draft basis. Please contact Alexandra M. Ledbetter, Staff Attorney, at (202) 551 -3317 or me a t (202) 551-3419 with any questions. Sincerely, /s/ Christian Windsor Christian Windsor Special Counsel cc: Via E -mail Andrés V. Gil Davis Polk & Wardwell LLP