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SECURITIES AND EXCHANGE COMMISSION

Washington, D.C. 20549

FORM 6-K

Report of Foreign Private Issuer
Pursuant to Rule 13a-16 or 15d-16 of the

Securities Exchange Act of 1934

For the month of November, 2016

Commission File Number 1-14732

COMPANHIA SIDERÚRGICA NACIONAL

(Exact name of registrant as specified in its charter)

National Steel Company

(Translation of Registrant's name into English)

Av. Brigadeiro Faria Lima 3400, 20º andar
São Paulo, SP, Brazil
04538-132

(Address of principal executive office)

Indicate by check mark whether the registrant files or will file annual reports
under cover Form 20-F or Form 40-F.  Form 20-F ___X___ Form 40-F _______

 Indicate by check mark whether the registrant by furnishing the information contained in this Form is also thereby furnishing the information to the Commission pursuant to Rule 12g3-2(b) under the Securities Exchange Act of 1934.

Yes _______ No ___X____

November 14, 2016

Via EDGAR Transmission

Mr. Terence O’Brien
Branch Chief
Office of Manufacturing and Construction
United States Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549-4631

Re:      National Steel Company
Form 20-F for the fiscal year ended December 31, 2015
Filed May 16, 2016
File No. 1-14732
Response Letter dated August 25, 2016

Dear Mr. O’Brien:

Reference is made to the comment letters from the staff of the United States Securities and Exchange Commission (the “Staff”) received by Companhia Siderúrgica Nacional (the “Company” or “CSN”) on October 28, 2016 and on June 22, 2016, concerning the Company’s annual report on Form 20-F for the fiscal year ended December 31, 2015, filed on May, 16, 2016 (the “2015 Form 20-F”). On August 25, 2016 we provided a letter with our responses to the Staff’s comments regarding the letter received on June 22, 2016. This letter provides the Company’s responses to the Staff’s comments in your October 28, 2016 letter. For your convenience, we have reproduced below in italics the Staff’s comments and have provided responses immediately below such comments. All page numbers referred to herein are to the 2015 Form 20-F.

SEC Comment No. 1.

Form 20-F for Fiscal Year Ended December 31, 2015

Operating and Financial Review and Prospects, page 74

Critical Accounting Estimates, page 82

Deferred Tax Assets, page 84

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1)                       We note your response to prior comment 1 in our letter to you dated June 22, 2016. Please ensure that you provide similar clarifying information in your filing. Refer to Section 501.14 of the Financial Reporting Codification for guidance.

Response to Comment No. 1.

We will include this information in future filings.

SEC Comment No. 2.

Financial Statements

Statements of Income, page F-3

Statements of Changes in Stockholders’ Equity, page F-6

2)                       We note you are still discussing your responses to prior comments 4 and 5 with your auditors. Please provide responses to these comments as soon as possible.

Response to Comment No. 2.

As a result of our discussions of our responses to prior comments 4 and 5 with our auditors we revisited the treatment of non-controlling interests in our consolidated financial statements from the business combination of Namisa. As explained in greater detail below, we have changed the accounting treatment of the allocation between controlling and non-controlling interests of the gains resulting from the Namisa business combination. As result of this change (an error in the previous presentation), we have filed with the Brazilian Securities Commission (Comissão de Valores Mobiliários - CVM) today a restatement of our statutory consolidated financial statements as of and for the year ended December 31, 2015 to reflect the new accounting treatment and will amend our Form 20-F as soon as practicable. We have also filed today a current report on Form 6-K to inform investors that in light of the restatement the financial statements included in our 2015 Form 20-F should no longer be relied upon.

Namisa Business Combination

As mentioned in note 3 to our consolidated financial statements, on November 30, 2015, we acquired the majority control of Namisa and merged it with our subsidiary Congonhas Minérios S.A. Prior to the transaction, we held a 100% interest in Congonhas and, after the issuance of shares to the Asian Consortium (“JKTC”), we reduced our equity interest in Congonhas to 87.52%, as shown below:

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Ø  Prior structure

Ø  Implementation of the transaction: issuance of new shares of Congonhas in exchange for JKTC’s contribution JKTC of its 40% interest in Namisa and cash-acquisition by CSN from JKTC of an additional 4.16% interest in Congonhas

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Ø  Post business combination structure, including acquisition by us from JKTC of additional 4.16% interest in Congonhas

As a result of the new shareholder’s agreement, Congonhas began controlling Namisa and applied IFRS 3 to account for the transaction. The application of the acquisition method on the business combination resulted in the following effects on Congonhas’ statement of income:

—   Remeasurement of the previously held equity interest (IFRS 3.42) in the amount of R$1.9 billion;

—   Elimination of the pre-existing relationship (IFRS 3.51) resulting in a gain in the amount of R$1.6 billion.

These gains were fully recognized at the Congonhas level, the acquirer of Namisa.

The accounting treatment that we revisited concerns the timing of recognition of the above gains by the shareholders of Congonhas, whether after the admission of JKTC (i.e. allocation of 87.52 % of the gain to CSN and of 12.48% of the gain on the transaction to JKTC), as originally applied by us, or before the admission of JKTC (i.e. allocation of 100% of the gain to CSN), as applied by us in the restatement.

All steps of the business combination, including the issuance of shares by Congonhas and the amendments to the shareholder’s agreement occurred on November 30, 2015 (the “Acquisition Date”).

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Original accounting treatment of non-controlling interests (reflected in our 2015 Form 20-F)

We applied the purchase method of accounting, which resulted in the recognition of the gains, on the Acquisition Date. We based the original accounting treatment to allocate gains between controlling and non-controlling interests on the actual corporate order of the following events occurred on that date.

The first corporate event was the issuance of Congonhas shares to JKTC, representing 12.48% of Congonhas’ equity interest, in exchange for JKTC contributing its 40% equity interest in Namisa. As a result, Congonhas became the direct owner of a 40% interest in Namisa and our interest in Congonhas was diluted from 100% to 83.36%, with no loss of control.

After the admission of JKTC to Congonhas a new Namisa shareholders’ agreement was signed providing majority control in Namisa to Congonhas, even though CSN continued to hold directly its 60% interest. After the new Namisa shareholders’ agreement provided Congonhas with the majority control of Namisa, Congonhas applied IFRS 3 and recognized gains that were shared by both shareholders, CSN and JKTC, at their respective equity interests at the time of 87.52% and 12.48%.

At the time of the business combination the previous understanding was that Congonhas already had two shareholders, CSN and JKTC, and for that reason the gains thereof, including on the 60% interest in NAMISA previously held by CSN, was shared with JKTC at its equity interest of 12.48%.

Therefore, considering the order of the corporate events occurred on the Acquisition Date, our original interpretation was that the gains on the business combination occurred after the admission of JKTC in the shareholding structure of Congonhas.

Revised accounting treatment of non-controlling interests (reflected in our restated statutory financial statements)

Upon revisiting the accounting treatment of these transactions we concluded that, independently of the order of the corporate events on the Acquisition Date, the business combination gains should be attributed exclusively to CSN and no share should be given to JKTC, even though JKTC acquired its 12.48% interest in Congonhas as the first corporate step on that date.

According to the revised accounting procedure also under IFRS 3, the gains resulted from the business combination were recorded in Congonhas before the admission of JKTC in its share capital, being attributed solely to CSN.

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The chart below summarizes the two accounting treatments:

Effects of restatement

The adjustments reflected in our restatement amount to R$359.9 million and are demonstrated as follows:

   in R$ million1

   Fair value measurement of the 60% investment in Namisa

   2,792

   Gain on settlement of preexisting relationships

   621

   Gains on business combination before income tax / social contribution

   3,413

   Income tax / social contribution on the gain of the preexisting relationships

   (528)

   Total impact of business combination

   2,885

   Gain percentage unduly allocated to non-controlling interests

   12.48%

   Gain unduly allocated to non-controlling interests

   360

1 The amounts presented in the table refer to 100% of the gains. In the consolidated financial statements, we presented these amounts considering the elimination of our previously held 60% interest in Namisa.

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As a result of adopting the revised accounting treatment of non-controlling interests in connection with the Namisa business combination at Congonhas, we have restated our statutory financial statements and filed with the Brazilian Securities Commission (Comissão de Valores Mobiliários - CVM) to adjust amounts in our consolidated shareholders’ equity and statement of income as follows:

Consolidated Financial Statements / Balance Sheet

   Consolidated

   12/31/2015

   As originally published

   Adjustments

   Restated

   ASSETS

   Current

   16.430.691

   16.430.691

   Non-current

   32.219.283

   32.219.283

   Long-term receivables

   4.890.948

   4.890.948

   Investments

   3.998.227

   3.998.227

   Property, plant and equipment

   17.871.599

   17.871.599

   Intangible assets

   5.458.509

   5.458.509

   Total assets

   48.649.974

   48.649.974

   LIABILITIES

   Current

   5.325.571

   5.325.571

   Non-current

   34.588.740

   34.588.740

   Shareholders’ equity

   8.735.663

   8.735.663

   Issued capital

   4.540.000

   4.540.000

   Capital reserves

   30

   30

   Earnings reserves

   2.104.804

   359.897

   2.464.701

   Other comprehensive income

   1.019.913

   (359.897)

   660.016

   Non-controlling interests

   1.070.916

   1.070.916

   Total liabilities

   48.649.974

   48.649.974

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Consolidated Financial Statements / Statement of Income

   Consolidated

   12/31/2015

   As originally published

   Adjustments

   Restated

   Net revenue

   15.331.852

   15.331.852

   Cost of sales and/or services

   (11.799.758)

   (11.799.758)

   Operating income (expenses)

   1.645.531

   1.645.531

   Selling expenses

   (1.436.000)

   (1.436.000)

   General and administrative expenses

   (470.368)

   (470.368)

   Equity in income of affiliates

   1.160.348

   1.160.348

   Other operating income (expenses)

   2.391.551

   2.391.551

   Profit before finance income (expenses)

   5.177.625

   5.177.625

   Finance income (expenses)

   (3.373.050)

   (3.373.050)

   Profit (loss) before taxes

   1.804.575

   1.804.575

   Income tax and social contribution

   (188.624)

   (188.624)

   Profit (loss) for the year

   1.615.951

   1.615.951

   Attributed to:

   Controlling Shareholders

   1.257.896

   359.897

   1.617.793

   Non-controlling Shareholders

   358.055

   (359.897)

   (1.842)

   1.615.951

   1.615.951

SEC Comment No. 3.

Note 2- Summary of Significant Accounting Policies, page F-8

2.a.a) Restatement of accounting balances, page F-23

3)                       We have read your response to prior comment 6. With reference to amounts reflected in prior periods, please explain how the interest and foreign exchange differences related to the forfaiting and drawee risk transactions that were previously accounted for in your statement of cash flows. Also, please explain the nature of the line item “forfaiting amortization,” and address whether this line item includes non-cash interest expense. If so, explain your basis for including these amounts in your statement of cash flows. Finally, please provide us with a reconciliation of the differences in the reclassification amounts between your balance sheets and cash flow statements in 2013 and 2014, with separate identification of the interest and foreign exchange differences.

Response to Comment No. 3.

According to the accounting procedure adopted before the reclassification, those transactions were recorded as trade accounts payable in the balance sheet considering its nominal amounts rather than

as loans and financings. Accordingly, in the statements of cash flow, those amounts were classified under operating activities, in the line item “trade payables,” within “increase (reduction) of liabilities.” Interest paid was presented in the line item “interests paid,” also under operating activities. The exchange rate effects, when materialized, were disclosed in the line item “accounts payable.”

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After the reclassification from trade accounts payable to loans and financing, the line item “forfaiting amortization” includes the settlement of the principal amounts of such transactions as financing activities. This line item does not include any type of interest.

The reconciliation of our balance sheet and cash flow is provided below:

   Movement of Forfaiting and drawee risk - 2013 and 2014

   2013

   2014

   Opening balance sheet amounts

   482.887

   42.265

   Capitalization (a)

   62.592

   641.430

   Amortization of principal (b)

   (587.569)

   (276.754)

   Interests paid (c)

   (13.116)

   (2.078)

   Exchange rate variation accrued over the years (d)

   97.472

   65.816

   Closing balance sheet amounts

   42.265

   470.679

   Cash flow reconciliation

   2013

   2014

   Forfaiting and drawee risk variation

   (440.622)

   428.414

   Exchange rate variation and interest paid (c) + (d)

   84.355

   63.738

   Cash (paid) received - (a) + (b)

   (524.977)

   364.676

SEC Comment No. 4.

2.n) Concessions, page F-16

4)                       We have read your response to prior comment 7. Please confirm that you will disclose the amount of your assets which are subject to reversion to the grantor.

Response to Comment No. 4.

We will include this information in future filings.

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SEC Comment No. 5.

Note 3- Business Combinations – Acquisition of control of Nacional Minerios (Namisa), page F-25

5)                       We note your response to prior comment 10. Please confirm that this contract was not cancelable. Also, if there was a settlement provision, please describe its terms.

Response to Comment No. 5.

The pre-existing ROM and Port Services agreements, referred on comment 10 of the letter dated June 22, 2016, provided for termination without cause only in the event of force majeure/acts of God or with cause upon a material breach of the contracts, therefore, they were not cancelable at the discretion of the parties. In the event of breach of contract by Namisa and/or force majeure/act of God, the agreements only established that the anticipated amounts should be returned pro rata, without providing for a pre-set settlement mechanism. We note that the cancellation occurred as a result of the merger of the two parties to the agreement, Namisa