SEC Comment Letter 0000000000-23-000461 to CREDIT SUISSE GROUP AG (CIK 0001159510)
CREDIT SUISSE GROUP AG (CIK 0001159510)
Date: Jan. 17, 2023 · CIK: 0001159510 · Accession: 0000000000-23-000461
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United States securities and exchange commission logo
January 17, 2023
Dixit Joshi
Chief Financial Officer
Credit Suisse AG
Paradeplatz 8
8001 Zurich, Switzerland
Re:Credit Suisse AG
Form 20-F for the Fiscal Year Ended December 31, 2021
Response Dated November 18, 2022
File No. 001-33434
Dear Dixit Joshi:
We have reviewed your November 18, 2022 response to our comment letter and 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 business days by providing the requested
information or advise us as soon as possible when you will respond. If you do not believe 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. Unless we note otherwise, our references to prior comments are to comments in our
October 20, 2022 letter.
Form 20-F for the Fiscal Year Ended December 31, 2021
Notes to the Consolidated Financial Statements
Note 1 - Summary of Significant Accounting Policies
Revisions of prior period financial statements, page 466
1.We note your response to prior comments 2 and 3. We continue to have questions as to
the actual control(s) that were deficient. For each identified control deficiency, please
address the following:
•Identify the deficient control(s), provide a description of how each control was
designed to address the related risk of material misstatement, and explain whether the
deficiency related to the design or operating effectiveness of the control.
•Provide management’s root cause analysis. In your response, tell us how the root
cause(s), including instances where the root cause is related to the knowledge
FirstName LastNameDixit Joshi
Comapany NameCredit Suisse AG
January 17, 2023 Page 2
FirstName LastNameDixit Joshi
Credit Suisse AG
January 17, 2023
Page 2
assessment and technical accounting expertise of the control owner, impact your
conclusions around entity level controls.
•Describe any remediation efforts, including the nature and timing of remediation, and
how the remedial actions address the related root cause(s).
2.We note your response to prior comment 1 states that you perform an accounting Quality
Assurance Review that focuses on a specific accounting topic, documenting and
reviewing the way such topic is addressed across relevant entities and systems within the
Group to ensure appropriate treatment. Your response further explained that the
consolidated statement of cash flows was included in this review and that this
management review was compensating in nature for the cash flow mapping deficiencies
identified. For each control deficiency identified, please explain how you determined that
management’s compensating controls compensate for the root cause(s) of the deficient
controls. Specifically, for each compensating control, please explain and provide the
following:
•The objective of the review control. For example, explain whether the control looks
at how transactions should be treated and whether the treatment was properly
implemented.
•The level of aggregation at which the control is performed.
•The frequency of the control.
•The correlation of the control’s design to each of the risks of material misstatement
related to these errors.
•The level of predictability of management’s expectations in their review.
•The criteria for investigating deviations or differences from expectations and how
those criteria correlate to management’s materiality evaluation. As part of this
response, explain whether the control identified any outliers in the operation of the
control.
•Quantification of the level of precision and magnitude of the potential error that these
compensating controls are designed to detect.
3.We note your response to prior comment 2 discusses how you evaluated the severity of
each of the identified control deficiencies. It appears your analysis primarily focused on
the actual size of the errors identified rather than the potential magnitude. For each
control deficiency identified, please respond to the following:
•Describe the factors that affected the magnitude of the misstatement that might result
from the deficiency, including (i) the total monetary amount of transactions exposed
to the deficiency and (ii) the volume of activity in the account balance or class of
transactions exposed to the deficiency in the current period or that is expected in a
future period.
•Quantify the magnitude of the potential misstatement for each of the identified
control deficiencies.
•Explain whether the qualitative factors also included considerations of other impacts,
such as regulatory requirements and other ratios.
FirstName LastNameDixit Joshi
Comapany NameCredit Suisse AG
January 17, 2023 Page 3
FirstName LastName
Dixit Joshi
Credit Suisse AG
January 17, 2023
Page 3
4.We note your response to prior comment 2, which states that, as it related to the mapping
deficiency, the likelihood of the potential misstatement was remote and the magnitude of
the potential misstatement was not material. In addition, the response states that, for the
nonfunctional currency gains and loss deficiency, the likelihood of potential misstatement
was reasonably possible, but the magnitude of the potential misstatement was not
material. Please explain in more detail how you performed the severity analysis for each
of the control deficiencies related to the errors. As part of your response, please address
the following:
•Explain in more detail how you supported the conclusions outlined above related to
the likelihood of potential misstatements and the potential magnitude for each
deficiency.
•Since the control deficiencies remained un-remediated for multiple years, tell us how
this was considered in the evaluation of the severity of the control deficiencies.
•Given that a restatement of previously issued financial statements for a correction of
an error is an indicator of a material weakness, explain how you considered the
restatement of previously issued financial statements to reflect the correction of these
errors, as described in Note 1 of your 2021 Form 20-F, in your evaluation of whether
the control deficiencies represented a material weakness.
•Provide management’s aggregation analysis of all control deficiencies identified for
the period.
You may contact Cara Lubit at 202-551-5909 or Robert Klein at 202-551-3847 if you
have questions regarding comments on the financial statements and related matters.
Sincerely,
Division of Corporation Finance
Office of Finance
cc: Sebastian Sperber