SecProbe.io

July 6, 2015

Via E -mail
Daniel Alberto Rodriguez Cofré
Chief Financial Officer
Mexican Economic Development, Inc.
General Anaya No. 601 Pte.
Colonia Bella Vista
Monterrey, NL 64410 Mexico

Re: Mexican Economic Development, Inc.
 Form 20-F for the Year Ended December 31, 2014
Filed April 21, 2015
File No. 001 -35934

Dear Mr. Cofré :

We have reviewed your filing an d have the following comments.  In some of our
comments, we may ask you to provide us with information so we may better understand your
disclosure.

Please respond to these comments  within ten busine ss days by providing the requested
information or advis e us as soon as possible when you will respond.  If you  do not bel ieve our
comments apply to your facts and circumstances , please tell us why in your response.

After reviewing your response to these  comments, we may have additional comments.

Form 20 -F for the Year Ended December 31, 2014

Audited Consolid ated Financial Statements of Fomento Economico Mexicano, S .A.B. de C.V
Notes to the Co nsolidated Financial Statements , page F -7
Note 10. Investments in Associates and Joint Ventures, page F -43

1. We note from the disclosure included on page F -44 and elsewhere in your filing that from
the date of your acquisition of a 51% investment in CCFPI through De cember 31, 2014,
the results of CCFPI have been recognized by Coca -Cola FEMSA using the equity
method of accounting. We also note that your use of the equity method is based on the
following factors: (i) during the initial four -year period from the acquisi tion date, some
relevant activities require joint approval between Coca -Cola FEMSA and The Coca -Cola
Company; and (ii) the potential voting rights to acquire the remaining 49% of CCFPI
provided by the put right obtained in the acquisition are not probable to be executed in
the foreseeable  future due to the fact that the call option is out of the money at both

Daniel Alberto Rodriguez Cofré
Mexican Economic Development, Inc.
July 6, 2015
Page 2

 December 31, 2014 and 2013. Please tell us and revise the notes to your financial
statements in future filings to explain in further detail the nature  of the activities that
require joint approval between Coca -Cola FEMSA and The Coca -Cola Company during
the initial four -year period following your acquisition of the 51% interest in this entity.
Also, please explain in further detail why you believe the j oint approval of these activities
results in a lack of control over CCFPI and the resultant need for consolidation of this
entity pursuant to IFRS 10, when it appears that you have majority voting control over
this entity as a result of your 51% interest.  Please provide your proposed disclosures as
part of your response.

Note 12. Intangible Assets, page F -50
Sensitivity to Changes in Assumptions, page F -54

2. We note from your disclosure on page F -54 that Coca -Cola FEMSA performed an
additional impairment s ensitivity calculation, taking into account an adverse change in
post-tax change in Weighte d Average Cost of Cap ital, according to the country risk
premium, using for each country the relative standard deviation between equity and
sovereign bonds and an additional sensitivity to the volume of 100 basis points, except
for Costa Rica, and concluded that no impairment would be recorded. Please explain why
Costa Rica was excluded from the additional sensitivity analysis using 100 basis points
consistent with the other countries and indica te whether an impairment charge with
respect to Costa Rica’s goodwill and distribution rights would have been required had its
indefinite -lived intangible assets been subject to the 100 -basis -point sensitivity analysis
used for the other countries.

Note 2 3. Earnings per S hare, page F -88

3. Please tell us and revise Note 23 to clearly explain how net income attributable to the
controlling interest is allocated between the Series B and Series D shares for purposes of
your earnings per share computations. Please provide your proposed disclosures as part
of your response.

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 Exchange Act rules require.   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.

Daniel Alberto Rodriguez Cofré
Mexican Economic Development, Inc.
July 6, 2015
Page 3

 In respon ding to our comments, please provide  a written statement from the company
acknowledging that:

 the company is responsible for the adequacy and accuracy of the disclosure in the filing;

 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 State s.

You may contact Suying Li  at (202) 551 -3335 or Linda Cvrkel at (202) 551 -3813 if you
have questions regarding comments on the financial statements and related matters.

Sincerely,

 /s/Tia L. Jenkins

Tia L. Jenkins
Senior Assistant Chief Accountant
Office of Beverages, Apparel , and
Mining