United States securities and exchange commission logo
July 15, 2022
David R. Mathers
Chief Financial Officer
Credit Suisse AG
Paradeplatz 8
8001 Zurich, Switzerland
Re: Credit Suisse AG
Form 20-F for the
Fiscal Year Ended December 31, 2021
Filed March 10,
2022
File No. 001-33434
Dear Mr. Mathers:
We have limited our review of your filing to the financial
statements and related
disclosures and have the following comments. In some of our comments, we
may ask you to
provide us with information so we may better understand your disclosure.
Please respond to these comments 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
comments apply to your facts and circumstances, please tell us why in
your response.
After reviewing your
response to these comments, we may have additional comments.
Form 20-F for the Fiscal Year Ended December 31, 2021
Critical Accounting Estimates
Current expected credit loss, page 106
1. We note that the
allowance for credit losses is estimated based on management's
assessment of several
factors, including probability of default, loss given default and
exposure at default as
well as historical frequency, current trends and conditions and
macroeconomic factors
such as regional gross domestic product, unemployment rates and
interest rates. Please
provide us proposed revised disclosure to be included within future
filings that address
the following items:
identifies key
quantitative inputs in your baseline estimate of the allowance for credit
losses;
quantifies the
qualitative component(s) of your estimate and explains or shows how it
interacts with the
quantitative component during the period presented;
provides a
sensitivity analysis quantifying a hypothetical impact or range of impact to
David R. Mathers
FirstName LastNameDavid R. Mathers
Credit Suisse AG
Comapany
July NameCredit Suisse AG
15, 2022
July 15,
Page 2 2022 Page 2
FirstName LastName
the allowance for credit losses due to changes in the key inputs;
and
details the length of time in your reasonable and supportable
forecasts and the
reversion method you applied after the reasonable and supportable
forecast period, if
applicable.
Refer to Item 303(b)(3) of Regulation S-K and ASC 326-20-50-11.
Controls and procedures, page 457
2. We note your disclosure that there were no changes in your internal
controls over
financial reporting ("ICFR") that have materially affected, or are
reasonably likely to
materially affect, your ICFR. In light of your accounting issues and
resulting revisions, as
well as the various changes that have taken place during 2021 with
regards to processes,
procedures, organizational and business structure, and senior
management, please provide
us with your analysis supporting your conclusion that there were no
material changes to
ICFR.
Notes to the consolidated financial statements
Note 1 - Summary of significant accounting policies
Revisions of prior period financial statements, page 466
3. We note your disclosures that you identified accounting issues
pertaining to: (i) netting
treatment in the presentation of a limited population of certain
securities lending and
borrowing activities; and (ii) reclassification and other changes to
the consolidated
statements of cash flows in the years ended December 31, 2020 and
2019. Please provide
us with a full and detailed description of the errors, including, but
not limited to, who
identified them, when, and how, and whether they were the result of
control
deficiencies. In addition, provide us with your assessment of
materiality supporting your
conclusion that they are immaterial both individually and in the
aggregate. Ensure your
response addresses qualitative and quantitative factors and provides
an objective
assessment of materiality from the perspective of a reasonable
investor, including your
consideration of guidance in ASC 250, SAB 99, and management s
assessment of
the design and effectiveness of ICFR.
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 Cara Lubit at 202-551-5909 or Robert Klein at
202-551-3847 with any
questions.
Sincerely,
Division of
Corporation Finance
David R. Mathers
Credit Suisse AG
FirstName
July LastNameDavid R. Mathers
15, 2022
Page 3
Comapany NameCredit Suisse AG
July 15, 2022 Page 3 Office of Finance
FirstName LastName