February 19,
2009

Francisco Noguera Rocha
Consul General of the Republic of Colombia
	in the City of New York
Consulate of Colombia
10 East 46 Street
New York, New York 10017

Re:	Republic of Colombia
      Registration Statement under Schedule B
      Filed January 23, 2009
      File No. 333-156913

      Form 18-K
      Filed September 10, 2008
      Form 18-K/A
      Filed January 20, 2009
      File No. 333-73840

Dear Mr. Consul:

	We have reviewed your filing and have the following comments.
Where indicated, we think you should revise your document in
response
to these comments.  If you disagree, we will consider your
explanation as to why our comments are inapplicable or revision is
unnecessary.  Please be as detailed as necessary in your
explanation.

	Please understand that the purpose of our review process is
to
assist you in your compliance with the applicable disclosure
requirements and to enhance the overall disclosure in your filing.
We look forward to working with you in these respects.  We welcome
any questions you may have about our comments or on any other
aspect
of our review.  Feel free to call us at the telephone numbers
listed
at the end of this letter.



General

Please update all statistics to provide the most recent data
possible.

Where appropriate, please discuss how the global economic crisis
has
affected and may continue to affect Colombia`s economy.
Specifically, discuss which sectors of the Colombian economy may
be
most affected by the adverse global economic environment and the
measures that the Government has taken or plans to take in
response
to the global economic crisis.

Form 18-K filed September 10, 2008, Exhibit D:

We refer you to pages D-5 and D-7.  In your discussion of the
presidential elections, please discuss the Supreme Court ruling
that
the election procedures were improper.  (See, for example,
"Colombia`s Uribe calls for election repeat," International Herald
Tribune, June 27, 2008).

We refer you to page D-8.  Please elaborate on the statement
"Guerilla organizations have increased their violence and
terrorism
in recent years, largely, the Government believes, in response to
the
Government`s successful efforts to eradicate illicit crops and
destroy drug processing and distribution centers."  Specifically,
describe the efforts that the Government has undertaken and how
the
Government measures their success. (See "Coca Cultivation Rises in
Colombia, U.N. Says," Washington Post, June 19, 2008.)

Please disclose Government actions taken following the alleged
actions of the army to increase the reported number of guerilla
deaths.  (See "Upping the Body Count," Economist, Oct. 20, 2008).

We refer you to the discussion of relations between the United
States
and Colombia on page D-52.  Please clarify whether the United
States
Congress has passed the bilateral trade agreement with Colombia
and
whether that agreement is in effect.  Additionally, consider
updating
this discussion to reflect the current status of the ATPDEA, which
remained in effect until December 31, 2008.

Consider revising your discussion of economic relations between
Colombia and Venezuela on pages D-52 through D-53 to reflect the
recent pledge between President Alvaro Uribe and President Hugo
Chavez of Venezuela to invest $100 million each in a special fund
to
boost cross-border trade between the two countries.




Please consider including a description of any material change in
relations between Colombia and the United States as a result of
the
change in the new presidential administration in the United
States.

Form 18-K/A filed January 20, 2009

Republic of Colombia, page 3

If material, consider discussing in greater detail any political
uncertainty posed by President Alvaro Uribe`s consideration of
whether he will run for a third term.

Foreign exchange rates and international reserves, page 10

Please update the figures in your discussion to reflect the
current
value of the peso.

Public sector internal debt, page 12

Please expand your disclosure on page 13 to include a discussion
of
the Finance Ministry`s recent announcement that it will seek to
exchange internal debt that matures in 2009 and 2011 for treasury
bonds with redemption dates in 2012, 2014, 2018.

Closing Comment

      Please revise your registration statement in response to our
comments.  You may wish to provide us with marked copies of the
revised registration statement to expedite our review.  Please
furnish a cover letter with your revised registration statement
that
keys your responses to our comments and provides any requested
supplemental information.  Detailed cover letters greatly
facilitate
our review.  Please understand that we may have additional
comments
after reviewing your revised registration statement.

	We direct your attention to Rules 460 and 461 of the
Securities
Act regarding requests for acceleration.  Please allow adequate
time
after the filing of any amendment for further review before
submitting a request for acceleration.  Please provide this
request
at least two business days in advance of the requested effective
date.




      Please direct any questions about these comments to me at
(202)
551-3450.

	Sincerely,


	Michael Coco
	Special Counsel



Cc: via facsimile
Mark H. Stumpf, Esq.
Arnold & Porter LLP
555 Twelfth Street, NW
Washington, D.C.  20004
Fax: (202) 942-5999
Republic of Colombia
February 19, 2009
1



UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549

         DIVISION OF
CORPORATION FINANCE