United States securities and exchange commission logo
January 17, 2023
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
November 18, 2022
File No. 001-15244
Dear Dixit Joshi:
We have reviewed your November 18, 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
October 20, 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 comments 2 and 3. We continue to have questions as to
the actual control(s)
that were deficient. For each identified control deficiency, please
address the following:
Identify the
deficient control(s), provide a description of how each control was
designed to
address the related risk of material misstatement, and explain whether the
deficiency related
to the design or operating effectiveness of the control.
Provide management
s root cause analysis. In your response, tell us how the root
cause(s),
including instances where the root cause is related to the knowledge
Dixit Joshi
FirstName LastNameDixit
Credit Suisse Group AG Joshi
Comapany
January 17,NameCredit
2023 Suisse Group AG
January
Page 2 17, 2023 Page 2
FirstName LastName
assessment and technical accounting expertise of the control
owner, impact your
conclusions around entity level controls.
Describe any remediation efforts, including the nature and
timing of remediation, and
how the remedial actions address the related root cause(s).
2. We note your response to prior comment 1 states that you perform an
accounting Quality
Assurance Review that focuses on a specific accounting topic,
documenting and
reviewing the way such topic is addressed across relevant entities and
systems within the
Group to ensure appropriate treatment. Your response further explained
that the
consolidated statement of cash flows was included in this review and
that this
management review was compensating in nature for the cash flow mapping
deficiencies
identified. For each control deficiency identified, please explain how
you determined that
management s compensating controls compensate for the root cause(s)
of the deficient
controls. Specifically, for each compensating control, please explain
and provide the
following:
The objective of the review control. For example, explain whether
the control looks
at how transactions should be treated and whether the treatment
was properly
implemented.
The level of aggregation at which the control is performed.
The frequency of the control.
The correlation of the control s design to each of the risks of
material misstatement
related to these errors.
The level of predictability of management s expectations in
their review.
The criteria for investigating deviations or differences from
expectations and how
those criteria correlate to management s materiality
evaluation. As part of this
response, explain whether the control identified any outliers in
the operation of the
control.
Quantification of the level of precision and magnitude of the
potential error that these
compensating controls are designed to detect.
3. We note your response to prior comment 2 discusses how you evaluated
the severity of
each of the identified control deficiencies. It appears your analysis
primarily focused on
the actual size of the errors identified rather than the potential
magnitude. For each
control deficiency identified, please respond to the following:
Describe the factors that affected the magnitude of the
misstatement that might result
from the deficiency, including (i) the total monetary amount of
transactions exposed
to the deficiency and (ii) the volume of activity in the account
balance or class of
transactions exposed to the deficiency in the current period or
that is expected in a
future period.
Quantify the magnitude of the potential misstatement for each of
the identified
control deficiencies.
Explain whether the qualitative factors also included
considerations of other impacts,
such as regulatory requirements and other ratios.
Dixit Joshi
Credit Suisse Group AG
January 17, 2023
Page 3
4. We note your response to prior comment 2, which states that, as it
related to the mapping
deficiency, the likelihood of the potential misstatement was remote and
the magnitude of
the potential misstatement was not material. In addition, the response
states that, for the
nonfunctional currency gains and loss deficiency, the likelihood of
potential misstatement
was reasonably possible, but the magnitude of the potential misstatement
was not
material. Please explain in more detail how you performed the severity
analysis for each
of the control deficiencies related to the errors. As part of your
response, please address
the following:
Explain in more detail how you supported the conclusions outlined
above related to
the likelihood of potential misstatements and the potential
magnitude for each
deficiency.
Since the control deficiencies remained un-remediated for multiple
years, tell us how
this was considered in the evaluation of the severity of the control
deficiencies.
Given that a restatement of previously issued financial statements
for a correction of
an error is an indicator of a material weakness, explain how you
considered the
restatement of previously issued financial statements to reflect the
correction of these
errors, as described in Note 1 of your 2021 Form 20-F, in your
evaluation of whether
the control deficiencies represented a material weakness.
Provide management s aggregation analysis of all control
deficiencies identified for
the period.
You may contact Cara Lubit at 202-551-5909 or Robert Klein at
202-551-3847 if you
have questions regarding comments on the financial statements and related
matters.
Sincerely,
FirstName LastNameDixit Joshi
Division of
Corporation Finance
Comapany NameCredit Suisse Group AG
Office of Finance
January 17, 2023 Page 3
cc: Sebastian Sperber
FirstName LastName