United States securities and exchange commission logo
October 20, 2022
Dixit Joshi
Chief Financial Officer
Credit Suisse Group AG
Paradeplatz 8
8001 Zurich, Switzerland
Re: Credit Suisse Group
AG
Form 20-F for the
Fiscal Year Ended December 31, 2021
Response Dated
August 22, 2022
File No. 001-15244
Dear Dixit Joshi:
We have reviewed your August 22, 2022 response to our comment
letter 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. Unless we note otherwise, our references to prior comments are
to comments in our
July 15, 2022 letter.
Form 20-F for the Fiscal Year Ended December 31, 2021
Notes to the Consolidated Financial Statements
Note 1 - Summary of Significant Accounting Policies
Revisions of Prior Period Financial Statements, page 292
1. We note your response
to prior comment 3 relating to the reclassification and other
changes to the
consolidated statements of cash flows and the related SAB 99 materiality
analysis provided for
the errors identified. Your response notes that you conducted a
detailed review of
reporting processes supporting the consolidated cash flow statements in
the second half of
2021. Explain in more detail the factors driving this review. In
addition, your response
notes that the review was part of a series of self-identified
enhancements to the
accounting control environment in recent years. Please tell us
whether you conducted
detailed reviews of the reporting processes supporting the other
Dixit Joshi
FirstName LastNameDixit
Credit Suisse Group AG Joshi
Comapany
October 20,NameCredit
2022 Suisse Group AG
October
Page 2 20, 2022 Page 2
FirstName LastName
consolidated financial statements, and, if so, when those reviews were
conducted.
2. Your response to comment 3 indicates that control deficiencies were
identified where
inappropriate mapping rules were used and that the automated rules
relating to the share-
based compensation and cash flow hedges were remediated prior to the
filing of the 2021
Form 20-F. Please address the items below.
Clarify whether these control deficiencies were determined to be a
significant
deficiency.
Your response indicates that the remediation of the rules relating
to the non-
functional currency gains and losses is expected to be completed
in 2022. Please
clarify whether the same control deficiency (deficiencies) was
(were) identified
related to the non-functional currency gains and losses and/or
whether there were
additional control deficiencies related to this error.
As part of your response, explain each of the control deficiencies
in more detail, as
well as how you concluded that they did not rise to the level of a
material weakness
given the nature of the control deficiencies (at least several
mapping rule errors) and
the fact that they led to quantitative errors exceeding 10% of the
respective line items
for several periods.
3. In addition to the comments above, please explain in more detail the
nature of the non-
functional currency gains and losses error, in which you only recorded
the gains and
losses on a subsection of re-measured assets as a reconciling item
between net income and
net cash provided by / (used in) operating activities, and why you
believe this change was
appropriate. By way of example only, your response indicates that
after observing a range
of practices, you decided to extend the existing processes to include
a broader selection of
instruments; however, given that there are a range of practices, it is
unclear how you
concluded that this was the appropriate approach. It is also unclear
why this change
would only include additional instruments, rather than all
instruments. As part of your
response, tell us the types of instruments this new practice does not
apply to and why, and
the presentation used for the remaining instruments.
4. We note your SAB 99 materiality analysis and the quantitative data
provided in Exhibit A
as part of your response to comment 3. We also note that you
acknowledge in your
response that the statement of cash flows errors exceed 5% of the
impacted line items, but
based on qualitative factors, you do not consider the changes to the
comparative periods to
be material to users of the financial statements. Please address the
items below.
Your materiality analysis briefly addresses the qualitative
factors enumerated in SAB
99, but SAB 99 also states this is not an exhaustive list of
the circumstances that
may affect the materiality of a quantitatively small misstatement.
Tell us whether
you considered other qualitative factors in concluding that the
errors were not
material, including any quantitative or qualitative metrics or
disclosures related to
liquidity and cash flows.
Your materiality analysis quantifies the impact of the statement
of cash flow errors on
the years ended December 31, 2020 and 2019. Please tell us how far
you believe the
Dixit Joshi
Credit Suisse Group AG
October 20, 2022
Page 3
errors go back and whether you quantified the impact on periods
prior to December
31, 2019. Additionally, please clarify whether you evaluated the
impact of the errors
on your quarterly consolidated statements of cash flows filed on
Forms 6-K, and, if
so, provide the results of that analysis.
Your response addresses the quantitative impact of the errors
on an aggregate basis
but does not address the quantitative impact on an individual
basis. Provide us with
an analysis that quantifies the individual impact for all of the
cash flow error
adjustments described in your response for all applicable
periods.
You may contact Cara Lubit at 202-551-5909 or Robert Klein at
202-551-3847 with any
questions.
FirstName LastNameDixit Joshi Sincerely,
Comapany NameCredit Suisse Group AG
Division of
Corporation Finance
October 20, 2022 Page 3 Office of Finance
FirstName LastName