View:
Mail Stop 4561
September 22, 2005
Walter Bayly
Chief Financial and Accounting Officer
Credicorp Ltd.
Calle Centenario 156
La Molina
Lima 12, Peru
RE: Credicorp Ltd.
Form 20-F for Fiscal Year Ended December 31, 2004
Filed June 30, 2005
File No. 1-14014
Dear Mr. Bayly,
We have reviewed the above referenced filing and have the
following comments. Where indicated, we think you should revise
your
document in response to these comments. If you disagree, we will
consider your explanation as to why our comment is inapplicable or
a
revision is unnecessary. Please be as detailed as necessary in
your
explanation. In some of our comments, we may ask you to provide
us
with information so we may better understand your disclosure.
After
reviewing this information, we may raise additional comments.
Please understand that the purpose of our review process is
to
assist you in your compliance with the applicable disclosure
requirements and to enhance the overall disclosure in your filing.
We look forward to working with you in these respects. We welcome
any questions you may have about our comments or any other aspect
of
our review. Feel free to call us at the telephone numbers listed
at
the end of this letter.
Selected Financial Data, page 5
1. It appears to us that the disclosed pro-forma diluted net
income
per common share is a non-GAAP financial measure. Please revise to
include non-GAAP disclosures required by Item 10(e) of Regulation
S-
K, or advise us.
Loan Portfolio, page 65
2. We note that you present the allocation of loan loss reserves
table on page 75 using the four categories specified by SBS
Resolution No. 808-2003 listed in the last paragraph on page 69.
Using the same four categories, please revise to present for the
past
five years:
* a breakdown of your loan portfolio; and
* write-offs and recoveries of write-offs in your loan loss
reserve
table on page 74.
Refer to Instruction 3 to Item IV.A of Industry Guide 3.
3. Please revise your discussion of changes in provision for loan
losses on page 86 to incorporate the enhanced disclosures provided
in
response to our preceding comment so as to provide a clear
understanding of the reasons for the changes in the allowance for
loan losses for each of the periods presented.
4. Please revise to disclose whether any past due loans still
accrue
interest and the amount of interest income recognized on these
loans
for the past 5 years. Refer to Item III.C of Industry Guide 3.
Contractual Obligations, page 98
5. Please revise to include all disclosures of your contractual
obligations required by Item 5(F) Part I of Form 20-F.
Report of Independent Auditors, page F-3
6. Please revise to include an updated audit report replacing the
first word in the third sentence of the second paragraph to "Our"
from "An". The language in the current opinion appears to imply
that
an audit cannot include a consideration of internal control over
financial reporting for the purpose of issuing an opinion on the
effectiveness of the Company`s internal control over financial
reporting. We recognize that your auditors are currently not
required
to include an attestation report on management`s assessment of the
issuer`s internal control over financial reporting.
Consolidated cash flow statements, page F-11
7. You refer the reader to notes 2(c) and (d) for the amounts
attributable to acquisition of subsidiaries net of cash received.
Please provide us with a reconciliation of the amounts presented
in
the notes to those presented in the statements of cash flows.
Note 2. Business developments, page F-13
8. We note that in October 2004 you entered into a definitive
agreement to sell your 100% interest in Banco Tequendama S.A. but
maintained control of its operations on December 31, 2004. Please
tell us how you considered the guidance in IAS 35, Discontinuing
Operations, as superceded by IFRS 5, Non-current Assets Held for
Sale
and Discontinued Operations, in accounting for this asset held for
sale. Also tell us how you determined that disclosure of a
reconciling item in Note 26 was not required considering the
guidance
in SFAS No. 144.
Note 3(r). Significant accounting policies - Workers` profit
sharing
and income tax, page F-23
9. Please revise to clearly state whether your accounting policies
for income tax and workers` profit sharing are in accordance with
International Financial Reporting Standards.
Note 17. Stock appreciation rights, page F-48
10. Please tell us how you determined that the granted stock
appreciation rights did not have any dilutive impact on your
earnings
per share calculations considering the guidance in IAS 33 and SFAS
No. 128.
As appropriate, please amend your filing and respond to these
comments within 10 business days or tell us when you will provide
us
with a response. You may wish to provide us with marked copies of
the amendment to expedite our review. Please furnish a cover
letter
with your amendment that keys your responses to our comments and
provides any requested information. Detailed cover letters
greatly
facilitate our review. Please file your letter on EDGAR. Please
understand that we may have additional comments after reviewing
your
responses to our comments.
We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filing to be certain that the
filing includes all information required under the Securities
Exchange Act of 1934 and that they have provided all information
investors require for an informed decision. Since the company and
its management are in possession of all facts relating to a
company`s
disclosure, they are responsible for the accuracy and adequacy of
the
disclosures they have made.
In connection with responding to our comments, please
provide,
in writing, a statement from the company acknowledging that:
* the company is responsible for the adequacy and accuracy of the
disclosure in the filing;
* staff comments or changes to disclosure in response to staff
comments do not foreclose the Commission from taking any action
with
respect to the filing; and
* the company may not assert staff comments as a defense in any
proceeding initiated by the Commission or any person under the
federal securities laws of the United States.
In addition, please be advised that the Division of
Enforcement
has access to all information you provide to the staff of the
Division of Corporation Finance in our review of your filing or in
response to our comments on your filing.
You may contact Michael Volley, Staff Accountant, at (202)
551-
3437 or me at (202) 551-3423 if you have questions regarding our
comments.
Sincerely,
Amit Pande
Assistant Chief Accountant
??
??
??
??
Walter Bayly
Credicorp Ltd.
September 22, 2005
Page 4