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599 Lexington Avenue +1.212.848.4000 |
May 28, 2021
CONFIDENTIAL SUBMISSION VIA EDGAR
Securities and Exchange Commission
Division of Corporation Finance
Office of International Corporate Finance
100 F Street, N.E.
Washington, D.C. 20549
Attention: Corey Jennings and Michael Coco
| Re: | Province of British Columbia Registration Statement under Schedule B Filed April 9, 2021 File No. 333-255142 |
Form 18-K for Fiscal Year Ended March 31,
2020 Filed October 14, 2020
Amended December 22, 2020, January 29, 2021 and April 26, 2021
File No. 333-82846
Ladies and Gentlemen:
On behalf of the Province of British Columbia (the “Province”), we are submitting this letter in response to our oral discussion (the “Oral Discussion”) and the prior written comments of the staff (the “Staff”) of the Securities and Exchange Commission (the “SEC”), as contained in your letter, dated May 3, 2021 (the “Comment Letter”), to the Province regarding the Province’s above-referenced registration statement (File No. 333-255142) under Schedule B, filed with the SEC on April 9, 2021 (the “Registration Statement”) and the annual report filed on Form 18-K (File No. 333-82846) for the fiscal year ended March 31, 2020, filed with the SEC on October 14, 2020 (the “Annual Report”), as amended on December 22, 2020, January 29, 2021 and April 26, 2021.
To facilitate your review of the Province’s responses, we have repeated your comment in italics followed immediately by the response of the Province.
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Form 18-K for Fiscal Year Ended March 31, 2020
Exhibit 99.5
| 6. | In your disclosure under “Labour Market” on page 47, we note your statement that “[w]omen and youth experienced outsized job losses, as they tend to be over-represented in some of the hardest hit service sectors. However, as of October, while the level of youth employment was still relatively low compared to February, women were closer to their pre-pandemic employment levels than men.” Please include a chart that provides a breakdown of your labor market by age and gender. |
In response to this question and the Oral Discussion, the Province supplementally furnishes to the Staff the publicly available information prepared by BC Stats, the Province’s central statistical agency, based on data provided by Statistics Canada, Canada’s national statistical office, included in Appendix A hereto, outlining employment and unemployment levels in British Columbia, on an actual and seasonally adjusted basis, broken down by age and gender.
| 7. | In your discussion of Canadian real GDP on page 94, we note your reference that underlying the labor market figures were several key factors such as declines in both full- and part-time work, steep job losses in high-contact services and construction, overrepresentation of youth, women, and visible minorities among the unemployed; and rising long-term unemployment. To the extent practicable, please include a chart that corresponds with this information. Additionally, to the extent practicable, please include a discussion or statistics for the extent that your labor market materially differs from those of Canada. |
In response to this question and the Oral Discussion, the Province supplementally furnishes to the Staff the following publicly available information prepared by BC Stats, based on data provided by Statistics Canada:
| · | Appendix A hereto, outlining employment and unemployment levels in British Columbia, on an actual and seasonally adjusted basis, broken down by age and gender; |
| · | Appendix B hereto, outlining the Province’s employment levels by full-time and part-time status; |
| · | Appendix C hereto, outlining the Province’s employment levels by industry and occupation; and |
| · | Appendix D hereto, outlining unemployment rates in each of the Canadian provinces, including British Columbia, as well as federal Canadian unemployment rates. |
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We thank the Staff in advance for its consideration of this letter and hope the Staff finds that the foregoing answers are responsive to its comments. If you should have any questions or further comments with respect to the Registration Statement, please do not hesitate to contact me at (212) 848-7974.
| Yours very truly, | |
| /s/ Jason Lehner | |
| Jason Lehner |
cc: Khawar Nasim
Consulate General of Canada
David Latham
Director, Corporate Relations and Portfolio Settlements
Debt Management Branch, Provincial Treasury
Province of British Columbia
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 | NOTE: dueto relatively small samplesizesfrom which disaggregated data arederived, caution should beused in theinterpretation of month-to-month changesin theestimates. |
 | NOTE: dueto relatively small samplesizesfrom which disaggregated data arederived, caution should beused in theinterpretation of month-to-month changesin theestimates. Prepared by: BCStatsSource: Statistics Canada, Labour Force Survey. Reproduced and distributed on an "as is" basis with the permission of Statistics Canada. |
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 | APPENDIX C NOTE: Monthly percent changesarecalculated asmonth over previousmonth. |
 | NOTE: Monthly percent changesarecalculated asmonth over previousmonth. |
 | NOTES: 1. Occupation specific Unemployment Ratesincludeonly thoseunemployed who worked in thepast year. The"All Occupations" rateincorporatestotal unemployed persons which includesan "Occupation Unclassified" category. Dueto therelatively small samplesizesfrom which disaggregated data arederived, caution should beused in theinterpretation of month-to-month changesin theestimates. For theunemployed, industry or occupation isbased on thelast job held in thepreviousyear. No information iscollected on industry or occupation of job search. |
 | APPENDIX D Prepared by: BCStatsSource: Statistics Canada, Labour Force Survey. Reproduced and distributed on an "as is" basis with the permission of Statistics Canada. |