SEC Comment Letter 0000000000-25-004547 to REPUBLIC OF THE PHILIPPINES (CIK 0001030717)
REPUBLIC OF THE PHILIPPINES (CIK 0001030717)
Date: April 29, 2025 · CIK: 0001030717 · Accession: 0000000000-25-004547
AI Filing Summary & Sentiment
File numbers found in text: 333-11554, 333-286375
Letter
April 29, 2025 Senen T. Mangalile Consul General Republic of the Philippines Philippine Consulate General 556 Fifth Avenue New York, New York 10036-5095 Re:Republic of the Philippines Registration Statement under Schedule B Filed April 4, 2025 File No. 333-286375 _ Form 18-K for Fiscal Year Ended December 31, 2024 Filed April 4, 2025 File No. 333-11554 Dear Senen T. Mangalile: We have reviewed your registration statement and have the following comments. Please respond to this letter by amending your registration statement and providing the requested information. If you do not believe a comment applies to your facts and circumstances or do not believe an amendment is appropriate, please tell us why in your response. After reviewing any amendment to your registration statement and the information you provide in response to this letter, we may have additional comments. Registration Statement under Schedule B Description of the Securities, page 18 1.We note that in your registration statement on Schedule B filed in 2020, the Republic included a statement on risk associated with ranking provisions of the debt securities arising from the NML Capital, Ltd. v. Republic of Argentina ruling, which is no longer included in the current registration statement. Please advise on why this was removed or update the disclosure.
April 29, 2025 Page 2 Annual Report on Form 18-K, Exhibit 99.(D) Economy, page D-29 2.We note recent changes in US tariffs applied to Philippines and their neighbors and competitors. To the extent applicable, please update your disclosure as to what effects current tariff situation may have on Philippines' economy. We remind you that the company and its management are responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the staff. Refer to Rules 460 and 461 regarding requests for acceleration. Please allow adequate time for us to review any amendment prior to the requested effective date of the registration statement. Please contact Kateryna Kuntsevich at 202-320-3189 or Michael Coco at 202-551- 3253 with any other questions. Sincerely, Division of Corporation Finance Office of International Corporate Finance
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April 29, 2025
Senen T. Mangalile
Consul General
Republic of the Philippines
Philippine Consulate General
556 Fifth Avenue
New York, New York 10036-5095
Re:Republic of the Philippines
Registration Statement under Schedule B
Filed April 4, 2025
File No. 333-286375
_
Form 18-K for Fiscal Year Ended December 31, 2024
Filed April 4, 2025
File No. 333-11554
Dear Senen T. Mangalile:
We have reviewed your registration statement and have the following comments.
Please respond to this letter by amending your registration statement and providing
the requested information. If you do not believe a comment applies to your facts and
circumstances or do not believe an amendment is appropriate, please tell us why in your
response.
After reviewing any amendment to your registration statement and the information
you provide in response to this letter, we may have additional comments.
Registration Statement under Schedule B
Description of the Securities, page 18
1.We note that in your registration statement on Schedule B filed in 2020, the Republic
included a statement on risk associated with ranking provisions of the debt securities
arising from the NML Capital, Ltd. v. Republic of Argentina ruling, which is no
longer included in the current registration statement. Please advise on why this was
removed or update the disclosure.
April 29, 2025
Page 2
Annual Report on Form 18-K, Exhibit 99.(D)
Economy, page D-29
2.We note recent changes in US tariffs applied to Philippines and their neighbors and
competitors. To the extent applicable, please update your disclosure as to what effects
current tariff situation may have on Philippines' economy.
We remind you that the company and its management are responsible for the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action or absence
of action by the staff.
Refer to Rules 460 and 461 regarding requests for acceleration. Please allow adequate
time for us to review any amendment prior to the requested effective date of the registration
statement.
Please contact Kateryna Kuntsevich at 202-320-3189 or Michael Coco at 202-551-
3253 with any other questions.
Sincerely,
Division of Corporation Finance
Office of International Corporate
Finance