United States securities and exchange commission logo
February 22, 2022
Takumi Kitamura
Executive Managing Director and 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, 2021
Filed June 25, 2021
File No. 001-15270
Dear Mr. Kitamura:
We have limited our review of your filing to the financial
statements and related
disclosures and have the following comment. In our comment, we ask you
to provide us with
information so we may better understand your disclosure.
Please respond to this comment 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 our
comment applies to your facts and circumstances, please tell us why in
your response.
After reviewing your
response to this comment, we may have additional comments.
Form 20-F for the fiscal year ended March 31, 2021
Notes to the Consolidated Financial Statements
Note 20: Affiliated companies and other equity-method investees:
NREH, page F-130
1. You disclose that you
recognized an impairment charge during fiscal 2021 of 47,661
million related to your
equity method investment in Nomura Real Estate Holdings, Inc.
(NREH) based on the
period and extent to which the share price was below the carrying
value. You also
disclose that the difference between the carrying value of your
investment in NREH and
the associated underlying equity in the net assets of NREH of
37,140 million was
the result of the excess of the underlying equity in net assets over fair
value of the investment
at March 31, 2021. Please address the following and reference for
us, where appropriate,
the authoritative literature you rely upon to support your
accounting:
Takumi Kitamura
Nomura Holdings, Inc.
February 22, 2022
Page 2
We note that from September 2018 through March 31, 2021,
excluding the decline
between March 2020 and December 2020, the stock price of NREH has
been
relatively stable and subsequently increased higher than before
March 2020. Provide
us your analysis supporting the period and extent to which the
share price was below
the carrying value to support the recognition of the 47,661
million impairment
charge during the fourth quarter of fiscal 2021, including why an
impairment charge
was not recorded for the periods ending March 31, 2019 and March
31, 2020
considering the stock price activity during those periods, which
other than the
significant decline at the end of March 2020, appears to be
reasonably consistent with
trading beginning in December 2020.
Disaggregate by investment, affiliated companies and other
equity-method investees
for which a quoted market price is available and provide us a
rollforward for the
carrying amount of 340,909 million for each year from March 31,
2017 to March
31, 2021. At each year end tell us the fair value of each
depicted investment, your
ownership percentage and the related underlying equity in net
assets.
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.
You may contact Mark Brunhofer at 1-202-551-3638 or Michelle Miller at
1-202-551-
3368 with any questions.
FirstName LastNameTakumi Kitamura Sincerely,
Comapany NameNomura Holdings, Inc.
Division of
Corporation Finance
February 22, 2022 Page 2 Office of Finance
FirstName LastName