United States securities and exchange commission logo
April 26, 2023
Gabriela Tobias
Counsel to the Ministry of Economy & Finance
Rep blica Oriental del Uruguay
Embassy of Uruguay
1913 I Street N.W., Lobby
Washington, D.C. 20006
Ignacio Lagos
Counsel
Cleary Gottlieb Steen & Hamilton LLP
One Liberty Plaza
New York, NY 10006
Re: Rep blica Oriental
del Uruguay
Registration
Statement under Schedule B
Filed March 30,
2023
File No. 333-270970
color:white;"_
Form 18-K for the
year ended December 31, 2021
Filed September 1,
2022
File No. 333-07128
Dear Gabriela Tobias:
We have reviewed your filing 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 this letter by amending your filing and
providing the requested
information. If you do not believe our comments apply to your facts and
circumstances or do not
believe an amendment is appropriate, please tell us why in your
response.
After reviewing any amendment to your registration statement and
the information you
provide in response to these comments, we may have additional comments.
Schedule B filed March 30, 2023
General
Gabriela Tobias
FirstName LastNameGabriela
Rep blica Oriental del UruguayTobias
Comapany
April NameRep blica Oriental del Uruguay
26, 2023
April 226, 2023 Page 2
Page
FirstName LastName
1. We recognize your financial and economic statistics are subject to a
review process such
that certain of your data for 2017-2021 are preliminary. We also
recognize that Banco
Central is conducting a periodic re-basing of its national accounting
calculations,
including GDP. To the extent possible, please update all statistics
and information in the
registration statement and the Form 18-K to provide the most recent
data, including, for
example, the data between 2017 and 2021 referenced as preliminary in
the summary chart
on page D-14 of the Form 18-K filed on September 1, 2022.
2. Please explain or define all acronyms. For example, you state on page
D-41 that "To
diversify the energy matrix and obtain a constant supply of natural
gas, the successive
governments have considered different actions for the production of
LNG in Uruguay." It
appears "LNG" refers to liquefied natural gas. As another example, you
disclose on page
D-67 the ratio of "NLPs" to total loans and the provision for "NPLs"
ratio.
3. Please consider providing your Internet address, if available. See
Securities Act Rule 493.
4. You state on page D-52 that "Uruguay imports all of its oil and gas
supplies from various
international sources...Uruguay's economy is...exposed to fluctuations
in international oil
prices." Please provide updated disclosure of any material impact of
Russia's invasion of
Ukraine on Uruguay's economy, inflation, energy supply, or foreign
relations.
5. Please update your disclosure, as necessary, to include any material
updates relating to
your current drought. We note, for example, recent third party reports
discussing the
severity and duration of the current drought.
Description of Securities
Negative Pledge, page 8
6. Please clarify whether the Series A and Series B Collateralized Fixed
Rate Notes Due
2021 notes have been redeemed.
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.
Refer to Rules 460 and 461 regarding requests for acceleration. Please
allow adequate
time for us to review any amendment prior to the requested effective date of
the registration
statement.
Please contact Angie Kim, Special Counsel, at (202) 551-3535 or Michael
Coco, Office
Chief, at (202) 551-3253 with any questions.
Sincerely,
Gabriela Tobias
Rep blica Oriental del Uruguay
April 26, 2023
Page 3
FirstName LastNameGabriela Tobias
Division of Corporation Finance
Comapany NameRep blica Oriental del Uruguay
Office of International Corporate
April 26, 2023 Page 3 Finance
FirstName LastName