TEXT-EXTRACT 2 filename2.txt July 19, 2019 Sandip Rana Chief Financial Officer Franco-Nevada Corporation 199 Bay Street, Suite 2000 P.O. Box 285, Commerce Court Postal Station Toronto, Ontario M5L 1G9 Canada Re: Franco-Nevada Corporation Form 40-F for the Fiscal Year Ended December 31, 2018 Filed March 27, 2019 File No. 001-35286 Dear Mr. Rana: We have reviewed your filing and have the following comment. In some of our comments, we may ask you to provide us with information so we may better understand your disclosure. Please respond to this comment within ten business days by providing the requested information or advise us as soon as possible when you will respond. If you do not believe our comment applies to your facts and circumstances, please tell us why in your response. After reviewing your response to the comment, we may have additional comments. Form 40-F for the Fiscal Year Ended December 31, 2018 Exhibit 99.2 Management's Discussion and Analysis Internal Control Over Financial Reporting and Disclsoure Controls and Procedures, page 32 1. Please disclose management's conclusion regarding the effectiveness of your disclosure controls and procedures as of December 31, 2018 or tell us where you have provided this required disclosure. Refer to Item B(6)(b) of Form 40-F. Sandip Rana Franco-Nevada Corporation July 19, 2019 Page 2 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. You may contact Myra Moosariparambil at 202-551-3796 or Craig Arakawa at 202-551- 2650 with any questions. Sincerely, FirstName LastNameSandip Rana Division of Corporation Finance Comapany NameFranco-Nevada Corporation Office of Beverages, Apparel and July 19, 2019 Page 2 Mining FirstName LastName