European Investment Bank
100 Boulevard Konrad Adenauer
L-2950 Luxembourg
Jonathan G. Katz
Secretary
Securities and Exchange Commission
450 Fifth Street, NW
Washington, DC 20549-0609
United States of America
Luxembourg, 24 January 2005
SG-JU/ACF/FI - 188
Dear Sir,
File No. S7-38-04: Release No. 33-8501
Securities Offering Reform
The European Investment Bank ("the Bank") is an international organization created by the Treaty of Rome of 25th March 1957 establishing the European Community. The Bank has a subscribed capital in excess of EUR 163 billion and its members are the member states of the European Community. The Bank is a frequent issuer of debt securities, including debt securities that are registered with the Securities and Exchange Commission under Schedule B of the Securities Act.
The Bank is pleased to respond to the Commission's request for comments on the proposed reform of its regulations governing public securities offerings in the United States. The Bank welcomes the proposed reform.
We have benefited from reading the comment letter dated January 14, 2005 of the Issues and Trading in Securities Committee and the Capital Markets Forum of the International Bar Association. The Bank should like to associate itself with certain views expressed in that letter by respectfully urging the Commission to extend the proposed reforms to Schedule B issuers. Eligibility to qualify as a "well-known seasoned issuer" should be extended to Schedule B issuers that have issued in the last three years at least $1 billion aggregate amount of debt securities in offerings registered under the Securities Act and will register only debt securities. In the interests of efficiency, it is not proposed to repeat any further detail here; instead reference is made to pages 6 and 7 of the IBA comment letter just mentioned.
We thank you for your time. If you have any questions about our comments, we will be very happy to discuss them with you.
Yours faithfully,
EUROPEAN INVESTMENT BANK
[signed]
Nicola Barr
Legal Department
[signed]
Sandeep Dhawan
Capital Markets Department