United States securities and exchange commission logo
October 5, 2023
Joseph D. Tarry
President and Chief Executive Officer
Public Service Company of New Mexico
414 Silver Avenue SW
Albuquerque, New Mexico 87102
Re: Public Service
Company of New Mexico
PNM Energy
Transition Bond Company I, LLC
Registration
Statement on Form SF-1
Filed September 8,
2023
File Nos.
333-274433 and 333-274433-01
Dear Joseph D. Tarry:
We have reviewed your
registration statement and have the following comment(s).
Please respond to this letter by amending your registration
statement and providing the
requested information. If you do not believe a comment applies 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 this letter, we may have additional comments.
Registration Statement on Form SF-1
Form of Prospectus
Security for the Series A Bonds
Pledge of Collateral, page 86
1. We note that, in
addition to the energy transition property, the collection account and all
of its subaccounts will
also secure the bonds, including all amounts of cash, instruments,
investment property or
other assets on deposit therein or credited thereto from time to time
and all financial
assets and securities entitlements carried therein or credited thereto.
Please confirm whether
any of the underlying collateral will consist of securities for
purposes of Rule 190
under the Securities Act.
Joseph D. Tarry
FirstName LastNameJoseph D. Tarry
Public Service Company of New Mexico
Comapany
October NamePublic Service Company of New Mexico
5, 2023
October
Page 2 5, 2023 Page 2
FirstName LastName
Issuance of Additional Energy Transition Bonds or Other Similar Bonds, page 91
2. We note your disclosure here and elsewhere in the form of prospectus
regarding the
conditions of issuance of additional energy transition bonds by the
issuing entity. Please
confirm that additional issuances of securities issued by the issuing
entity will be
registered on separate registration statements or exempt.
Part II - Information Not Required in Prospectus
Item 14. Exhibits, page II-3
3. Please file your remaining exhibits with your next amendment. Refer to
Item 1100(f) of
Regulation AB and Instruction 1 to Item 601 of Regulation S-K. Note
that we may have
additional comments on your registration statement following our
review of any such
exhibits.
4. We note that throughout the registration statement you refer to the
"series supplement" to
the indenture. However, your list of exhibits does not include a form
of the series
supplement. Please confirm that the form of series supplement will be
attached as an
exhibit to the form of indenture, or else file a form of series
supplement as an exhibit to
your registration statement.
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 Benjamin Meeks at 202-551-7146 or Arthur Sandel at
202-551-3262 with
any other questions.
Sincerely,
Division of
Corporation Finance
Office of
Structured Finance