BANCO COMERCIAL PORTUGUES, S.A.
BCP INTERNATIONAL BANK LIMITED
BCP FINANCE COMPANY
October 13, 2003
Via EDGAR
Securities and Exchange Commission
Division of Corporation Finance
450 Fifth Street, N.W.
Washington, D.C. 20549
Re: Banco Comercial Portugues, S.A.
BCP International Bank Limited
BCP Finance Company
Request to Withdrawal Registration Statement on Form F-3
SEC File Number 333-13650
Ladies and Gentlemen:
Pursuant to Rule 477(a) promulgated under the Securities Act of 1933,
as amended (the "Securities Act"), Banco Comercial Portugues, S.A., BCP
International Bank Limited and BCP Finance Company (collectively, the
"Registrants") hereby respectfully request that the Securities and Exchange
Commission (the "Commission") consent to the withdrawal of the Registration
Statement on Form F-3 (File No. 333-13650) originally filed with the Commission
on June 22, 2001, together with all exhibits thereto (collectively, the
"Registration Statement"). The Registrants do not intend to conduct the offering
of securities contemplated in the Registration Statement. The Registrants
request that the Commission consent to this application on the grounds that the
withdrawal of the Registration Statement is consistent with the public interest
and the protection of investors, as contemplated by Rule 477(a) under the
Securities Act.
The Registrants confirm that no securities have been or will be issued
or sold pursuant to the Registration Statement or the prospectus contained
therein. The Registrants request, in accordance with Rule 457(p) under the
Securities Act, that all fees paid to the Commission in connection with the
filing of the Registration Statement be credited to the Registrants' account to
be offset against the filing fee for any future registration statement or
registration statements.
The Registrants hereby respectfully requests that the Commission issue
a written order granting the withdrawal of the Registration Statement. Please
fax a copy of the order to Banco Comercial Portugues, S.A. at (351) 21 321 10
79, Attention: Mr. Magalhaes Duarte, and to the Registrants' counsel, Richard L.
Russell, Esq. of Dorsey & Whitney LLP, at (212) 953-7201.
If you have any questions regarding this application for withdrawal, please
contact Mr. Russell at (212) 415-9242.
Very truly yours,
Banco Comercial Portugues, S.A.
By: Filipe Pinhal
--------------------------------------------
Name: Filipe Jesus Pinhal
Title: Vice-Chairman of the Board of Directors
By: Antonio Rodrigues
--------------------------------------------
Name: Antonio M. Seabra e Melo Rodrigues
Title: Member of the Board of Directors
BCP International Bank Limited
By: Luis Gomes
--------------------------------------------
Name: Luis Manuel Neto Gomes
Title: Chairman of the Board of Directors
By: Antonio Fernando Nogueira Chaves
--------------------------------------------
Name: Antonio Fernando Nogueira Chaves
Title: Vice-Chairman of the Board of Directors
BCP Finance Company
By: Luis Gomes
--------------------------------------------
Name: Luis Manuel Neto Gomes
Title: Chairman of the Board of Directors
By: Antonio Fernando Nogueira Chaves
--------------------------------------------
Name: Antonio Fernando Nogueira Chaves
Title: Vice-Chairman of the Board of Directors
cc: Richard L. Russell, Esq.
2