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SEC Comment Letter for BANK OF MONTREAL (BMO) — Nov 30, 2012

BANK OF MONTREAL /CAN/ (BMO, BERZ, BNKD, BNKU, BULZ, CARD, CARU, DULL, FLYD, FLYU, FNGD, FNGO, FNGS, FNGU, GDXD, GDXU, JETD) (CIK 0000927971)
Date: Nov. 30, 2012 · CIK: 0000927971 · Accession: 0000000000-12-064758

AI Filing Summary & Sentiment

Sentiment
Urgency
Document Type
Confidence
SEC Posture
Company Posture

Summary

Reasoning

Date
November 30, 2012
Author
/s/ Kevin W. Vaughn for
Form
UPLOAD
Company
BANK OF MONTREAL /CAN/ (BMO, BERZ, BNKD, BNKU, BULZ, CARD, CARU, DULL, FLYD, FLYU, FNGD, FNGO, FNGS, FNGU, GDXD, GDXU, JETD) (CIK 0000927971)

Letter

November 30, 2012 Via E -mail Thomas E. Flynn Chief Financial Officer Bank of Montreal 100 King Street West 1 First Canadian Place Toronto, Ontario Canada, M5X 1A1

Re: Bank of Montreal Form 40-F for the Fiscal Year Ended October 31, 2011 Filed December 6, 2011 Form 6 -K Filed August 28, 2012 File No. 001 -13354

Dear Mr. Thomas E. Flynn:

We have completed our review of your filings . We remind you that our comments or changes to disclosure in response to our comments do not foreclose the Commission from taking any action with respect to the company or the filing s and the company may not assert staff comments as a defense in any proceeding initiated by the Commission or any pers on under the federal securities laws of the United States. We urge all persons who are responsible for the accuracy and adequacy of the disclosure in the filing s to be certain that the filing s include the information the Securities Exchange Act of 1934 an d all applicable rules require.

Sincerely,
/s/ Kevin W. Vaughn for

Show Raw Text
November 30, 2012

Via E -mail
Thomas E. Flynn
Chief Financial Officer
Bank of Montreal
100 King Street West
1 First Canadian Place
Toronto, Ontario
Canada, M5X 1A1

Re: Bank of Montreal
 Form 40-F for the Fiscal Year Ended October 31, 2011
Filed December 6, 2011
 Form 6 -K
Filed August 28, 2012
File No. 001 -13354

Dear Mr. Thomas E. Flynn:

We have completed our review of your filings .  We remind you that our comments or
changes to disclosure in response to our comments do not foreclose the Commission from taking
any action with respect to the company or the filing s and the company may not assert staff
comments as a defense in any proceeding initiated by the Commission or any pers on under the
federal securities laws of the United States.  We urge all persons who are responsible for the
accuracy and adequacy of the disclosure in the filing s to be certain that the filing s include the
information the Securities Exchange Act of 1934 an d all applicable rules require.

Sincerely,

 /s/ Kevin W. Vaughn for

Stephanie J. Ciboroski
Senior Assistant Chief Accountant