June 8, 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,
On behalf of Nordic Investment Bank (“NIB” or the “Bank”), we are responding to the points that you raised in a telephone conversation with us on June 4, 2015, in connection with our letter dated June 2, 2015 (the “Response Letter”) setting forth NIB’s updated response to the comment letter of the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”) dated May 7, 2015, relating to the above-referenced Registration Statement under Schedule B and the annual report on Form 18-K for the fiscal year ended December 31, 2013 of NIB. With regard to the Staff’s comment no. 3 (reproduced below in bold for your convenience, along with the Bank’s response immediately below the comment) and the disclosure NIB intends to file in an amendment to its annual report on Form 18-K for the fiscal year ended December 31, 2014 (the “18-K/A”), contained in Exhibit A to the Response Letter, you requested that:
1. NIB revise the introductory paragraph of the disclosure to be included in the18-K/A; and
2. NIB provide Euro figures rather than percentages for the following economic data
for NIB’s member countries contained in the 18-K/A: (i) real GDP, (ii) balance of payments and (iii) public finance.
NIB has revised the draft 18-K/A in accordance with your requests.
***
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.
***
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. 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 capita) | ||||||||
| 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(1) (EUR per capita) | ||||||||
| 2014 | 43,300 | 13,100 | 34,100 | 33,700 | 10,600 | 11,200 | 67,300 | 40,400 |
| 2013 | 43,000 | 12,800 | 34,300 | 33,200 | 10,300 | 10,800 | 66,600 | 39,900 |
| 2012 | 43,400 | 12,600 | 34,900 | 32,400 | 9,800 | 10,300 | 66,900 | 39,700 |
| 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) (EUR millions) | ||||||||
| 2014(5) | 4,812.4 | 127.9 | 390.1 | n/a | -88.0 | -36.8 | 7,682.4 | 6,773.4 |
| 2013(5) | 5,495.3 | -10.0 | -382.3 | n/a | -54.0 | 403.4 | 11,224.8 | 7,096.0 |
| 2012(5) | 3,453.8 | -123.5 | -500.7 | n/a | -66.0 | 250.8 | 13,439.0 | 6,936.6 |
| Public Finance(6) (EUR millions) | ||||||||
| 2014 | 3,211.6 | 121.3 | -6,435.0 | n/a | -347.0 | -242.0 | 34,167.4 | -8,098.5 |
| 2013 | -2,684.9 | -40.0 | -5,122.0 | n/a | -172.4 | -916.9 | 44,534.8 | -5,989.8 |
| 2012 | -9,194.6 | -38.5 | -4,240.0 | n/a | -176.5 | -1,049.0 | 54,922.5 | -3,917.3 |
| 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) | Amounts shown are chain-linked through successive application of the GDP growth rates to the previous year’s prices, with the price figures of 2010 as the reference 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. |
| (5) | Amounts shown are for Q4. |
| (6) | Deficit or surplus. |
| (7) | Public debt as a percentage of GDP. |