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UPLOAD Filing

MEXICAN ECONOMIC DEVELOPMENT INC
Date: July 21, 2025 · CIK: 0001061736 · Accession: 0000000000-25-007670

Risk Disclosure Regulatory Compliance Financial Reporting

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File numbers found in text: 001-35934

Date
July 21, 2025
Author
Division of
Form
UPLOAD
Company
MEXICAN ECONOMIC DEVELOPMENT INC

Letter

Re: Mexican Economic Development Inc. Form 20-F for the Fiscal Year Ended December 31, 2024 Filed April 24, 2025 File No. 001-35934 Dear Alejandro Gil Ortiz:

July 21, 2025

Alejandro Gil Ortiz General Counsel Mexican Economic Development Inc. General Anaya No. 601 Pte. Colonia Bella Vista Monterrey, NL 64410 Mexico

We have limited our review of your filing to the financial statements and related disclosures and have the following comments.

Please respond to this letter within ten business days by providing the requested information or advise us as soon as possible when you will respond. If you do not believe a comment applies to your facts and circumstances, please tell us why in your response.

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

Form 20-F for the Fiscal Year Ended December 31, 2024 Risk Factors Risks Related to Our Company, page 4

1. We note your disclosure at the bottom of page 8 regarding risks linked to international cartels and transnational criminal organizations present in jurisdictions that you have operations. We further note media sources indicate your OXXO operations in Nuevo Laredo, Mexico were temporarily closed in 2024 due to cartel related concerns. In future filings, please revise your disclosure to expand on the risks related to heightened criminal activity in Mexico. Your revised disclosure should address, but not be limited to, how criminal activity affects companies and employees through extortion, theft, kidnapping, and violence. If material, include impacts such as, lost income and associated costs due to store closures, increased insurance and security costs, theft, and extortion losses. Also, consider discussing how corruption and ties between criminal organizations and authorities may affect your operations and how July 21, 2025 Page 2

cartels may attempt to control the sale, distribution, and pricing of goods. Please provide us with your draft disclosure enhancements in your response. In closing, 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.

Please contact Mindy Hooker at 202-551-3732 or Kevin Stertzel at 202-551-3723 with any questions.

Sincerely,
Division of
Corporation Finance
Office of
Manufacturing

Show Raw Text
<DOCUMENT>
<TYPE>TEXT-EXTRACT
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<FILENAME>filename2.txt
<TEXT>
 July 21, 2025

Alejandro Gil Ortiz
General Counsel
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 Fiscal Year Ended December 31, 2024
 Filed April 24, 2025
 File No. 001-35934
Dear Alejandro Gil Ortiz:

 We have limited our review of your filing to the financial statements
and related
disclosures and have the following comments.

 Please respond to this letter within ten business days by providing the
requested
information or advise us as soon as possible when you will respond. If you do
not believe a
comment applies to your facts and circumstances, please tell us why in your
response.

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

Form 20-F for the Fiscal Year Ended December 31, 2024
Risk Factors
Risks Related to Our Company, page 4

1. We note your disclosure at the bottom of page 8 regarding risks linked
to international
 cartels and transnational criminal organizations present in
jurisdictions that you have
 operations. We further note media sources indicate your OXXO operations
in Nuevo
 Laredo, Mexico were temporarily closed in 2024 due to cartel related
concerns. In
 future filings, please revise your disclosure to expand on the risks
related to
 heightened criminal activity in Mexico. Your revised disclosure should
address, but
 not be limited to, how criminal activity affects companies and employees
through
 extortion, theft, kidnapping, and violence. If material, include impacts
such as, lost
 income and associated costs due to store closures, increased insurance
and security
 costs, theft, and extortion losses. Also, consider discussing how
corruption and ties
 between criminal organizations and authorities may affect your
operations and how
 July 21, 2025
Page 2

 cartels may attempt to control the sale, distribution, and pricing of
goods. Please
 provide us with your draft disclosure enhancements in your response.
 In closing, 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.

 Please contact Mindy Hooker at 202-551-3732 or Kevin Stertzel at
202-551-3723
with any questions.

 Sincerely,

 Division of
Corporation Finance
 Office of
Manufacturing
</TEXT>
</DOCUMENT>