SEC Comment Letter for BANK OF MONTREAL (BMO) — May 1, 2014
BANK OF MONTREAL /CAN/ (BMO, BERZ, BNKD, BNKU, BULZ, CARD, CARU, DULL, FLYD, FLYU, FNGD, FNGO, FNGS, FNGU, GDXD, GDXU, JETD) (CIK 0000927971)
Date: May 1, 2014 · CIK: 0000927971 · Accession: 0000000000-14-022062
AI Filing Summary & Sentiment
Referenced dates: March 28, 2014
Letter
April 30 , 2014 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 Fiscal Year Ended October 31, 2013 Filed December 3, 2013 File No. 1 -13354
Dear Mr. Flynn :
We refer you to our comment letter dated March 28, 2014, regarding business contacts with Cuba, Sudan and Syria. We have completed our review of this subject matter. 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 and the company may not assert staff comments as a defense in any proceeding initiated by the Commission or any person 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 to be certain that the filing includes the information the Securities Exchange Act of 1934 and all applicable rules require.
Sincerely,
/s/ Cecilia Blye
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April 30 , 2014
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 Fiscal Year Ended October 31, 2013
Filed December 3, 2013
File No. 1 -13354
Dear Mr. Flynn :
We refer you to our comment letter dated March 28, 2014, regarding business contacts
with Cuba, Sudan and Syria. We have completed our review of this subject matter. 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 and the company
may not assert staff comments as a defense in any proceeding initiated by the Commission or any
person 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 to be certain that the
filing includes the information the Securities Exchange Act of 1934 and all applicable rules
require.
Sincerely,
/s/ Cecilia Blye
Cecilia Blye, Chief
Office of Global Security Risk
cc: Suzanne Hayes
Assistant Director
Division of Corporati on Finance
Colleen Hennessy
Associate General Counsel
Legal, Corporate and Compliance Group
Bank of Montreal
Thomas E. Flynn
Bank of Montreal
April 30, 2014
Page 2
Paul Bachand
Associate General Counsel
Legal, Corporate and Compliance Group
Bank of Montreal