Subject: comment letter 3-20855
From:
Affiliation:

July 1, 2023

:The World Bank
COVID-19 Access to Finance DPF (P172863) Page 2 I have a non disclosure agreement margin covered buys authority to transfer sell invest withdrawal etc etc SUMMARY OF PROPOSED FINANCING AND PROGRAM BASIC INFORMATION Project ID modern day slavery act strategic modernization
P172863 No xxxxxxxx
Proposed Development Objective(s)
Contribute to the governments efforts to: (i) support liquidity in the financial sector, and (ii) establish instruments for improved financial access.
Organizations
Borrower: UNITED MEXICAN STATES
Implementing Agency: Notre Dame Modern day slavery act MINISTRY OF FINANCE AND PUBLIC CREDIT (SECRETARA DE HACIENDA Y CRDITO
PBLICO)
PROJECT FINANCING DATA (US$, Millions)
SUMMARY
Total Financing 1,000,000,000.00
DETAILS
International Bank for Reconstruction and Development (IBRD) 1,000,000,000.00 INSTITUTIONAL DATA Climate Change and Disaster Screening This operation has been screened for short and long-term climate change and disaster risks Overall Risk Rating Substantial The World Bank

COVID-19 Financial Access DPF (P172863)

Page 1
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UNITED MEXICAN STATES...................................................2
1. INTRODUCTION AND COUNTRY CONTEXT ....................................4
2. MACROECONOMIC POLICY FRAMEWORK.......................................7
2.1. RECENT ECONOMIC DEVELOPMENTS.......................................7
2.2. MACROECONOMIC OUTLOOK AND DEBT SUSTAINABILITY.....................12
2.3 IMF RELATIONS .....................................................15
3. GOVERNMENT PROGRAM .................................................15
4. PROPOSED OPERATION .................................................17
4.1. LINK TO GOVERNMENT PROGRAM AND OPERATION DESCRIPTION .............17
4.2. PRIOR ACTIONS, RESULTS AND ANALYTICAL UNDERPINNINGS ..............19
4.3. LINK TO CPF, OTHER BANK OPERATIONS AND THE WBG STRATEGY ..........30
4.4. CONSULTATIONS AND COLLABORATION WITH DEVELOPMENT PARTNERS ........31 
5. OTHER DESIGN AND APPRAISAL ISSUES ..................................32
5.1. POVERTY AND SOCIAL IMPACT.........................................32
5.2. ENVIRONMENTAL, FORESTS, AND OTHER NATURAL RESOURCE ASPECTS .......34
5.3. PFM, DISBURSEMENT AND AUDITING ASPECTS............................34
5.4. MONITORING, EVALUATION AND ACCOUNTABILITY ........................35
6. SUMMARY OF RISKS AND MITIGATION.....................................36
ANNEX 1: POLICY AND RESULTS MATRIX ....................................38
ANNEX 2: FUND RELATIONS ANNEX .........................................41
ANNEX 3: LETTER OF DEVELOPMENT POLICY..................................43
ANNEX 4: ENVIRONMENT AND POVERTY/SOCIAL ANALYSIS TABLE ................54
ANNEX 5: DETAILED POVERTY AND SOCIAL IMPACT ANALYSIS .................The World Bank
COVID-19 Financial Access DPF (P172863)
Mexico
United Mexican States
GOVERNMENT FISCAL YEAR
January 1 December 31
CURRENCY EQUIVALENTS
(Exchange Rate Effective as of April 21, 2020) Currency Unit MXN 24.41 = US$ 1 ABBREVIATIONS AND ACRONYMS CDD Customer Due Diligence CNBV National Banking and Assets Commission (Comisin Nacional Bancaria y de Valores) CONAFREC National Council of Civil Registry Officials (Consejo Nacional de Funcionarios del Registro Civil) CONAIF National Financial Inclusion Council (Consejo Nacional de Inclusin
Financiera)
CONAMER National Comission for Regulatory Improvement (Comisin Nacional de Mejora Regulatoria) CONDUSEF National Commission for the Defense and Protection of Financial Services Users (Comisin Nacional para la Proteccin y Defensa de los Usuarios de Servicios Financieros)
COVID-19 Coronavirus Disease 2019
CPF Country Partnership Framework
CPI Consumer Price Index
CURP Unique Population Registration
Number (Clave nica de Registro de
Poblacin)
DPF Development Policy Financing
DRM Monetary Regulation Deposit
(Depsito de Regulacin Monetaria)
EM Emerging Market
ENAFIN National Survey on Access to Finance for Firms (Encuesta Nacional de Financiamiento de las Empresas) ENIF National Financial Inclusion Survey (Encuesta Nacional de Inclusin
Financiera)
FCL Flexible Credit Line
FDI Foreign Direct Investment
FIGI Financial Inclusion Global Initiative FM Financial Management FSAP Financial Sector Assessment Program FY Fiscal Year GDP Gross Domestic Product GRS Grievance Redress Service IBRD International Bank for Reconstruction and Development ID Identification IFC International Finance Corporation IFPE Electronic Payment Funds Institutions (Instituciones de Fondos de Pagos Electrnicos) IMF International Monetary Fund INE National Electoral Institute (Institution Nacional Electoral) INEGI National Geography and Statistics Institute (Instituto Nacional de Estadstica y Geografa)56 If the units could be settled in stock at the holders election, so that if the holder were terminated currently he or she would get the underlying stock without the need to satisfy any additional vesting requirements, the registrant should report the total number of shares and percent of class beneficially owned, including the shares and percent of class beneficially owned due to the potential exercise of rights acquired under the phantom stock units. This is because the holder would have the right to acquire the underlying stock within 60 days (see Exchange Act Rule 13d-3). In addition to including the shares underlying the units in the total number of shares and percent of class beneficially owned, the phantom stock units also should be presented in a manner that distinguishes them from stock owned outright e.g., pursuant to a clear and succinct footnote explanation. In contrast, if the phantom stock units can be settled in stock only at the companys discr etion, they should not be reported in the total number of shares and percent of class beneficially owned, because the holder does not have a right to acquire the underlying stock within 60 days. Similarly, if the phantom stock units can be settled solely in cash, they should not be reported because the holder has no right to acquire the underlying stock. March 13, 2007

Question 2.03
Question: If a named executive officer died since the beginning of the registrants last fiscal year, must the deceased named executive officer be included in the Item 403(b) ownership table?

Answer: No. Although Item 403(b) requires disclosure for each of the named executive officers, as defined in Item 402(a)(3), a named executive officer who died since the beginning of the registrants last fiscal year would not need to be included in the Item 403(b) ownership table. March 13, 2007

Question 2.04
Question: Does the Item 403(b) requirement to indicate, by footnote or otherwise, the amount of shares that are pledged as security apply to a negative pledge of the companys stock by a director, nominee or named executive officer? (A negative pledge is a covenant granted by a borrower to a lender in which a promise is made not to convey the shares to a third party or to otherwise encumber them. Assuming a default by the borrower, the negative pledge would not transfer title by operation of law, but would instead require a foreclosure.)

Answer: Yes, because shares subject to a negative pledge may be subject to material risk or contingencies that do not apply to other shares beneficially owned by these persons, and such shares are pledged as security by operation of the negative pledge covenant. March 13, 2007

Section 3. Item 403(c) Changes in control Question 3.01
Question: Does the requirement in Item 403(c) to disclose any arrangement . . . including any pledge . . . which may at a subsequent date result in a change in control of the registrant apply to a negative pledge of the companys stock by a principal shareholder, as described in Question 2.04 above?

Answer: In the ordinary course, such an arrangement would not be disclosable under Item 403(c). However, the registrant should consider whether any circumstances, such as insolvency of the borrower or takeover activity with respect to the registrant, would render a change in control arising from such an arrangement foreseeable and, hence, disclosable under Item 403(c). March 13, 2007

INTERPRETIVE RESPONSES REGARDING PARTICULAR SITUATIONS Section 1. Item 403(a) Security ownership of certain beneficial owners
1.01 A limited partnership holds restricted voting securities in a company that plans to make a public offering of its securities. The limited partnership agreement requires the limited partnership to distribute the restricted securities to its general and limited partners within 60 days following such public offering. In light of the beneficial ownership provisions of Section 13(d), the beneficial ownership of shares to be held by the general and limited partners whose holdings will be in excess of 5 percent (or if such persons are directors or named executive officers) following such distribution should be included in the beneficial ownership table contained in the companys prospectus. March 13, 2007

1.02 When asked whether an issuer would be required to consider Form 13-F reports of investment discretion in determining the identity of 5 percent beneficial owners under Item 403(a), the Division staff advised that the concept of investment discretion was not the same as beneficial ownership, noting that investment managers subject to Form 13-F reporting would also have to file Schedule 13D or Schedule 13G if their interest in the securities constituted beneficial ownership. The Division staff emphasized the statement in Item 403 that the issuer could rely on Schedules 13D and 13G, but that such reliance could not be exclusive if it had knowledge (or has reason to believe that such information is not complete or accurate or that a statement or amendment that should have been filed was not) of any 5 percent beneficial owners who had not filed such reports. March 13, 2007

Section 2. Item 403(b) Security ownership of management
2.01 The tax consequences under Section 409A of the Internal Revenue Code that apply if a key employee receives a stock distribution within six months after leaving the company do not affect the analysis as to whether the person has a right to acquire the stock within 60 days under Rule 13d-3(d)(1). This is because Section 409A results in a negative economic consequence rather than a prohibition upon receipt of the shares. March 13, 2007

Section 3. Item 403(c) Changes in contro

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