SecProbe.io

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Mail Stop 6010
Via Facsimile and U.S. Mail

September 16, 2005

Mr. Gustavo Alcalde L.
Chief Executive Officer
Administradora de Fondos Pensiones Provida S. A.
Avenida Pedro de Valdivia 100
Santiago, Chile
Re:   Administradora de Fondos Pensiones Provida S. A.
          Form 20-F for Fiscal Year Ended December 31, 2004
          File No. 1-13406

Dear Mr. Alcalde:

      We have limited our review of your filing to those issues we
have addressed in our comments.  Where indicated, we think you
should
revise your document in response to these comments. 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
necessary in your explanation. In some of our comments, we may ask
you to provide us with information so we may better understand
your
disclosure.  After reviewing this information, we may raise
additional comments.

	Please understand that the purpose of our review process is
to
assist you in your compliance with the applicable disclosure
requirements and to enhance the overall disclosure in your filing.
We look forward to working with you in these respects.  We welcome
any questions you may have about our comments or any other aspect
of
our review.  Feel free to call us at the telephone numbers listed
at
the end of this letter.

Item 5. Operating and Financial Review and Prospects

Critical Accounting Policies

Accounting for Life and Disability Insurance Cost, page 61

1. Given the significance of unfavorable casualty rate adjustments
to
operating results and recent related accounting errors, we believe
that your disclosure regarding provision for unfavorable casualty
rate could be improved to better explain the judgments and
uncertainties surrounding these estimates and the potential impact
on
your financial statements. Disclosure explaining the likelihood
that
materially different amounts would be reported under different
conditions or using different assumptions is consistent with the
objective of Item 5 of Form 20-F. Accordingly, please include the
following information:

* Disclose the insurance contract provisions applicable to each
year
presented, particularly the terms of the rebate structure whereby
you
participate in favorable and unfavorable casualty rate experience
and
the net amount of risk borne by you. Quantify the impact of these
rebate provisions by contract for each year presented. Link this
discussion to the sections, Life and Disability Benefits on page
20
and Insurance Contract on page F-13.
* Disclose the objectives of your predictive model, its
methodology
and key assumptions utilized at each valuation date.
* Disclose whether a range of liability estimates are determined.
Discuss the key assumptions used to arrive at management`s best
estimate within that range and what specific factors led
management
to believe this amount rather than any other amount within the
range
represented the best estimate of incurred losses.
* Provide more precise insight into the existence and effects on
future operations and financial condition of known trends, such as
changes in claim frequency and severity. Link this disclosure to
your
discussion in liquidity and capital resources.

2. You appear to project casualty rate experience based upon
externally generated information (e.g. provided by BBVA Seguros in
2004 and ING Seguros for 2003). We believe that greater
uncertainty
related to your projection of these liabilities may exist due to
the
extent of your dependence on data generated by these third
parties.
Please include disclosures relating to your critical accounting
policy of the risks associated with making these estimates, such
as
the following:

* The time lag from when claims are reported to the insurer to
when
the insurer reports them to you and whether, how and to what
extent
this time lag effects your liability estimate;
* The amount of any backlog related to the processing of claim
information, whether the backlog has been reserved for in the
financial statements and, if applicable, when the backlog will be
resolved;
* The process management performs to determine the accuracy and
completeness of the information received;
* The nature of disputes with insurers and magnitude of related
amounts;
* How management resolves disputes and how often disputes have
occurred.

3. We note that while you discuss critical accounting policies
under
Chilean GAAP, you provide no corresponding discussion under US
GAAP.
Since you disclose that significant differences can exist between
Chilean GAAP and US GAAP, please identify your critical accounting
policies under US GAAP.  Provide an analysis and quantification of
the uncertainties in applying these accounting policies, the
historical accuracy of these critical accounting estimates, a
quantification of their sensitivity to changes in key assumptions
and
the expected likelihood of material changes in the future.
Please
refer to the Instructions to Item 5 of Form 20-F.

Operating Results, page 66

4. As indicated in Note 8 (c), it appears that you have revised
your
provisions for casualty rates recorded in prior years. For each of
these changes in estimate, please disclose the following
information:

* Identify the years to which the change in estimate relate and
the
amount of the related provision for higher casualty rate as of the
beginning of the year that was re-estimated.  Quantify changes in
estimates that increase and decrease the provision for higher
casualty rate.
* Link this discussion to the description of your insurance
contracts
in note 8 (b) and the details of life and disability insurance
adjustments in Note 8 (f).
* Identify the changes in the key assumptions you made to estimate
the provision since the last reporting date.
* Identify the nature and timing of the change in estimate,
explicitly identifying and describing in reasonable specificity
the
new events that occurred or additional information acquired since
the
last reporting date that led to the change in estimate.
* Explain why recognition occurred in the periods that it did and
why
recognition was not required in earlier periods.
* Explain the rationale for a change in estimate that does not
correlate with known trends, such as changes in casualty frequency
and severity.

5. We note that you provide no discussion of US GAAP operating
results when US GAAP and Chilean GAAP differ significantly. We
believe that the intent of Item 5 disclosure is to provide
investors
with a sufficient understanding of a company`s financial
statements
on a US GAAP basis, including the factors determining the quality
and
potential variability of earnings and cash flow so that they can
ascertain the likelihood that past performance is indicative of
future performance. Include a discussion of any aspects of the
differences between Chilean GAAP and US GAAP not discussed in the
reconciliation to US GAAP.  This disclosure should include a
discussion and quantification of the specific factors underlying
changes in your operating results and known trends and
uncertainties
that you believe are necessary for an understanding of the
financial
statements as a whole.  Please refer to the Instructions to Item 5
of
Form 20-F.

Contractual Obligations, page 79
6. We note that you have included certain estimated payments
associated with your life and disability policy signed with BBVA
Seguros. However, we were unable to relate the amount for other
contractual obligations to amounts disclosed in your financial
statements. Please provide disclosure that clearly links this
amount
to your financial statements. Include explanatory footnotes to
this
table as necessary.

Item 18. Consolidated Financial Statements

Note 41. Differences between Chilean and United States Generally
Accepted Accounting Principles

I. Differences in Measurement Methods, page F-56

7. It appears that revenue recognition under Chilean GAAP and US
GAAP
does not differ. Accordingly, your US GAAP revenue recognition
related to individual account administration appears to be on a
cash
basis and you recognize fee income only when "all activities
relating
to the administration of the Pension Fund have been completed".
Please provide a more detailed discussion of your revenue
recognition
under US GAAP that includes a clarification of the terminology in
Notes 2 (l) and 7 and your revenue recognition policy for both
fixed
and variable fees.

8. Your description of the accounting errors and related
restatements
of your Chilean GAAP financial statements and US GAAP
reconciliation
does not appear to adequately explain how you corrected these
errors.
In particular, we note your statement on page F-65 that errors
existed in the financial statements for the two years ended
December
31, 2003, yet you also recorded an adjustment in 2004. Also, on
page
F-65 you refer to an allocation of certain current year
adjustments
to prior years but provide no further explanation. Please provide
a
more detailed explanation and quantification of each adjustment
made
to prior year financial statements. Integrate this discussion with
restatement amounts shown on pages F-62 and F-63 and the
unfavorable
casualty rate adjustments shown on page F-16.

II. Additional Disclosure Requirements, page F-66

9. You identify a contingent liability relating to disability and
survival pensions and life annuities in Note 35 (b) amounting to
UF
1,187,718. Please provide a more detailed explanation of the
nature
of this contingent liability, the likelihood of your risk of loss
associated with this liability and the basis for your decision not
to
record the liability in your financial statements.

10. We note the existence of a number of related parties as
disclosed
in Notes 14 and 33. Rule 4-08 (k) of Regulation S-X requires all
amounts arising from related party transactions, such as your
purchase of insurance coverage from BBVA Seguros, be presented in
separate captions on the face of your financial statements. Please
expand your disclosure in section II b, Income Statement US GAAP,
to
include this information.

11. Based on your description of business starting on page 16, it
appears that you have reportable segments under SFAS 131.  For
example, it appears that your activities as pension fund
administrator and insurer of disability benefits as well as your
activities in foreign markets are reportable segments and do not
meet
the aggregation criteria in paragraph 17 of SFAS 131.  Please
disclose all reportable segments or explain to us how you have
complied with SFAS 131.

12. You state that under US GAAP, mandatory investments are
classified as trading securities as prescribed in SFAS 115. Please
provide all related US GAAP disclosure, including SFAS 115 and
concentration of credit disclosures under SFAS 107.
III. Recent Accounting Pronouncements, page F-73

13. We note that you omit discussion of FIN 46R, Consolidation of
Variable Interest Entities. Please disclose how you considered the
requirements of this technical pronouncement in preparing your
disclosure in Note 41.

*    *    *    *

      As appropriate, please amend your filing and respond to
these
comments within 10 business days or tell us when you will provide
us
with a response.  You may wish to provide us with marked copies of
the amendment to expedite our review. Please furnish a cover
letter
with your amendment that keys your responses to our comments and
provides any requested information.  Detailed letters greatly
facilitate our review.  Please understand that we may have
additional
comments after reviewing your amendment and responses to our
comments.

      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 all information required under the Securities
Exchange Act of 1934 and that they have provided all information
investors require for an informed investment decision.  Since the
company and its management are in possession of all facts relating
to
a company`s disclosure, they are responsible for the accuracy and
adequacy of the disclosures they have made.

	In connection with responding to our comments, please
provide,
in your letter, a statement from the company acknowledging that:

* the company is responsible for the adequacy and accuracy of the
disclosure in the filings;
* staff comments or changes to disclosure in response to staff
comments do not foreclose the Commission from taking any action
with
respect to 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.

	In addition, please be advised that the Division of
Enforcement
has access to all information you provide to the staff of the
Division of Corporation Finance in our review of your filing or in
response to our comments on your filing.

      You may contact Frank Wyman, Staff Accountant, at 202-551-
3660
or Don Abbott, Senior Staff Accountant, at 202-551-3608, if you
have
questions regarding the comments.  In this regard, do not hesitate
to
contact me, at (202) 551-3679.

							Sincerely,

							Jim B. Rosenberg
						Senior Assistant Chief Accountant
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Mr. Gustavo Alcalde L.
Administradora de Fondos Pensiones Provida S. A.
September 16, 2005
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