June 2, 2015
VIA EDGAR CORRESPONDENCE
Ms. Sandra B. Hunter Staff Attorney Securities and Exchange Commission Division of Corporation Finance 100 F Street, NE Washington, D.C. 20549
Re: Nordic Investment Bank Registration Statement under Schedule B Filed April 10, 2015 File No. 333-203363
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Dear Ms. Hunter,
We have received your comment letter (the “Comment Letter”) dated May 7, 2015 related to the above-referenced Registration Statement under Schedule B (the “RegistrationStatement”) and the annual report on Form 18-K for the fiscal year ended December 31, 2013 (the “2013 18-K”) of Nordic Investment Bank (“NIB” or the “Bank”). On May 18, 2015, we responded to the Comment Letter and filed our response as correspondence with the Securities and Exchange Commission (the “Commission”) via EDGAR. On May 21, 2015, we had a phone conversation with you, during which you reissued comment 3 contained in the Comment Letter. This letter contains our updated response to comment 3.
For your convenience, we have reproduced below in bold the comment of the staff of the Commission (the “Staff”) numbered to correspond with the numbers in the Comment Letter, and provided our response immediately below the comment.
Registration Statement under Schedule B
General
| 3. | To the extent material, consider providing summary information that includes the key economic data of each of the member countries, including nominal and real GDP, consumer price index, industrial product price index, unemployment, balance of payments, public finance and public debt figures. |
In response to the Staff’s comment, NIB will include the information contained in Exhibit A attached hereto in an amendment to its annual report on Form 18-K for the fiscal year ended December 31, 2014.
NIB also confirms to the Staff that the Bank will include the requested summary information in future filings with the Commission on Form 18-K or Form 18-K/A.
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We are grateful for your assistance in this matter. Please do not hesitate to call me at +49-69-97103-0 with any questions that you may have with respect to the foregoing.
| Very truly yours, Cleary Gottlieb Steen & Hamilton LLP | |
By: /s/ Ward A. Greenberg Ward A. Greenberg, a Partner |
cc: Sten Holmberg, Nordic Investment Bank
EXHIBIT A
the Member Countries
The following information has been extracted from publicly available sources. While we believe that the information is reliable, we have not independently verified it and we make no representation that it is accurate or complete. We undertake no obligation to update any of these figures or amend them if the public sources are subsequently revised.
As used herein, the terms “EUR” and “euro” refer to the currency introduced on January 1, 1999, and adopted by the economic and monetary union of the European Union (“EMU”) as the unit of account of the institutions of the European Communities as well as the currency of the nineteen participating member states of the EMU and the unit of account of the central banks of such member states. On December 31, 2014, the EUR/USD exchange rate as published by the European Central Bank was 1.2141 U.S. dollars per one euro. No representation is made that EUR amounts actually represented, or have been or could be converted into, U.S. dollars at such rate or at any other rates on such date.
Selected Demographic and Economic Data
The following table presents selected demographic and economic data for NIB’s member countries for the years indicated:
| Denmark | Estonia | Finland | Iceland | Latvia | Lithuania | Norway | Sweden | |
| Population | ||||||||
| 2014 | 5,627,235 | 1,315,819 | 5,451,270 | 325,671 | 2,001,468 | 2,943,472 | 5,107,970 | 9,644,864 |
| 2013 | 5,602,628 | 1,320,174 | 5,426,674 | 321,857 | 2,023,825 | 2,971,905 | 5,051,275 | 9,555,893 |
| 2012 | 5,580,516 | 1,325,217 | 5,401,267 | 319,575 | 2,044,813 | 3,003,641 | 4,985,870 | 9,482,855 |
| Nominal GDP (EUR millions) | ||||||||
| 2014 | 257,443.8 | 19,526.2 | 204,015.0 | 12,871.9 | 24,059.7 | 36,308.9 | 377,224.3 | 430,258.2 |
| 2013 | 252,938.9 | 18,738.8 | 201,995.0 | 11,583.3 | 23,265.0 | 34,955.6 | 393,098.4 | 436,342.4 |
| 2012 | 250,786.4 | 17,636.7 | 199,793.0 | 11,076.0 | 22,217.0 | 33,314.0 | 396,678.0 | 423,340.7 |
| Nominal GDP (EUR per inhabitant) | ||||||||
| 2014 | 45,600 | 14,800 | 37,400 | 39,500 | 12,100 | 12,400 | 73,400 | 44,400 |
| 2013 | 45,100 | 14,200 | 37,100 | 35,800 | 11,600 | 11,800 | 77,400 | 45,500 |
| 2012 | 44,900 | 13,300 | 36,900 | 34,500 | 10,900 | 11,200 | 79,000 | 44,500 |
| Real GDP Growth Rate(1) (in %) | ||||||||
| 2014 | 1.1 | 2.1 | -0.1 | 1.9 | 2.4 | 2.9 | 2.2 | 2.3 |
| 2013 | -0.5 | 1.6 | -1.3 | 3.6 | 4.2 | 3.3 | 0.7 | 1.3 |
| 2012 | -0.7 | 4.7 | -1.4 | 1.3 | 4.8 | 3.8 | 2.7 | -0.3 |
| Harmonized Consumer Price Index – Inflation Rate(2) (in %) | ||||||||
| 2014 | 0.3 | 0.5 | 1.2 | 1.0 | 0.7 | 0.2 | 1.9 | 0.2 |
| 2013 | 0.5 | 3.2 | 2.2 | 4.1 | 0.0 | 1.2 | 2.0 | 0.4 |
| 2012 | 2.4 | 4.2 | 3.2 | 6.0 | 2.3 | 3.2 | 0.4 | 0.9 |
| Industrial Product Price Index(3)(in %) | ||||||||
| 2014 | -1.0 | -1.6 | -0.9 | n/a | 0.4 | -4.9 | -1.4 | 1.4 |
| 2013 | 1.6 | 4.1 | -0.5 | n/a | 1.8 | -2.4 | 0.6 | -2.8 |
| 2012 | 2.3 | 2.3 | 1.4 | n/a | 3.7 | 5.0 | 2.8 | -0.9 |
| Unemployment (in %) | ||||||||
| 2014 | 6.6 | 7.4 | 8.7 | 5.0 | 10.8 | 10.7 | 3.5 | 7.9 |
| 2013 | 7.0 | 8.6 | 8.2 | 5.4 | 11.9 | 11.8 | 3.5 | 8.0 |
| 2012 | 7.5 | 10.0 | 7.7 | 6.0 | 15 | 13.4 | 3.2 | 8.0 |
| Balance of Payments(4) (in %) | ||||||||
| 2014(5) | 7.2 | 2.5 | 0.7 | n/a | -1.4 | -0.4 | 8.1 | 6.1 |
| 2013(5) | 8.5 | -0.2 | -0.7 | n/a | -0.9 | 4.5 | 11.4 | 6.3 |
| 2012(5) | 5.4 | -2.7 | n/a | n/a | -1.1 | 2.9 | 12.9 | 6.3 |
| Public Finance(6) (in %) | ||||||||
| 2014 | 1.2 | 0.6 | -3.2 | n/a | -1.4 | -0.7 | 9.1 | -1.9 |
| 2013 | -1.1 | -0.2 | -2.5 | n/a | -0.7 | -2.6 | 11.3 | -1.4 |
| 2012 | -3.7 | -0.2 | -2.1 | n/a | -0.8 | -3.1 | 13.8 | -0.9 |
| Public Debt(7) (in %) | ||||||||
| 2014 | 45.2 | 10.6 | 59.3 | n/a | 40.0 | 40.9 | 26.4 | 43.9 |
| 2013 | 45.0 | 10.1 | 55.8 | n/a | 38.2 | 38.8 | 29.3 | 38.7 |
| 2012 | 45.6 | 9.7 | 52.9 | n/a | 40.9 | 39.8 | 29.2 | 36.6 |
Source: Eurostat.
| (1) | Percentage change as compared to previous year. |
| (2) | Percentage change as compared to previous year. |
| (3) | Percentage change as compared to previous year. Excludes construction, sewerage, waste management and remediation activities. |
| (4) | Current account as a percentage of GDP |
| (5) | Amounts shown are for Q4. |
| (6) | Deficit or surplus as a percentage of GDP. |
| (7) | Public debt as a percentage of GDP. |