SEC Comment Letter 0000000000-24-002872 to NOMURA HOLDINGS INC (NMR, NRSCF) (CIK 0001163653) (NMR)
NOMURA HOLDINGS INC (NMR, NRSCF) (CIK 0001163653)
Date: March 15, 2024 · CIK: 0001163653 · Accession: 0000000000-24-002872
AI Filing Summary & Sentiment
File numbers found in text: 001-15270
Letter
United States securities and exchange commission logo March 15, 2024 Takumi Kitamura Chief Financial Officer Nomura Holdings, Inc. 13-1, Nihonbashi 1-chome Chuo-ku, Tokyo 103-8645 Japan Re:Nomura Holdings, Inc. Form 20-F for the Fiscal Year Ended March 31, 2023 File No. 001-15270 Dear Takumi Kitamura: We have limited our review of your filing to the financial statements and related disclosures and have the following comment. 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 March 31, 2023 Consolidated Statements of Cash Flows, page F-13 1.We note your disclosure that you have classified activities related to loans, net of allowance for credit losses as part of operating cash flows in the Consolidated Statements of Cash Flows. Please provide us with an accounting analysis supporting your conclusion that this activity is properly classified within cash flows from operating activities rather than cash flows from investing activities. Refer to ASC 230-10-45-12(e) and 13(a). 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 Jee Yeon Ahn at 202-551-3673 or Robert Klein at 202-551-3847 with any questions.
FirstName LastNameTakumi Kitamura Comapany NameNomura Holdings, Inc. March 15, 2024 Page 2 FirstName LastName Takumi Kitamura Nomura Holdings, Inc. March 15, 2024 Page 2 Sincerely, Division of Corporation Finance Office of Finance
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United States securities and exchange commission logo
March 15, 2024
Takumi Kitamura
Chief Financial Officer
Nomura Holdings, Inc.
13-1, Nihonbashi 1-chome
Chuo-ku, Tokyo 103-8645
Japan
Re:Nomura Holdings, Inc.
Form 20-F for the Fiscal Year Ended March 31, 2023
File No. 001-15270
Dear Takumi Kitamura:
We have limited our review of your filing to the financial statements and related
disclosures and have the following comment.
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 March 31, 2023
Consolidated Statements of Cash Flows, page F-13
1.We note your disclosure that you have classified activities related to loans, net of
allowance for credit losses as part of operating cash flows in the Consolidated Statements
of Cash Flows. Please provide us with an accounting analysis supporting your conclusion
that this activity is properly classified within cash flows from operating activities rather
than cash flows from investing activities. Refer to ASC 230-10-45-12(e) and 13(a).
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 Jee Yeon Ahn at 202-551-3673 or Robert Klein at 202-551-3847 with any
questions.
FirstName LastNameTakumi Kitamura
Comapany NameNomura Holdings, Inc.
March 15, 2024 Page 2
FirstName LastName
Takumi Kitamura
Nomura Holdings, Inc.
March 15, 2024
Page 2
Sincerely,
Division of Corporation Finance
Office of Finance