Skadden, Arps, Slate, Meagher & Flom llp
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40 BANK STREET
CANARY WHARF
LONDON E14 5DS
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TEL: (020) 7519-7000
FAX: (020) 7519-7070
www.skadden.com
July 11, 2019
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AFFILIATE OFFICES
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BOSTON
CHICAGO
HOUSTON
LOS ANGELES
NEW YORK
PALO ALTO
WASHINGTON, D.C.
WILMINGTON
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BEIJING
BRUSSELS
FRANKFURT
HONG KONG
MOSCOW
MUNICH
PARIS
SÃO PAULO
SEOUL
SHANGHAI
SINGAPORE
SYDNEY
TOKYO
TORONTO
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Republic of Italy
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U.S. Securities and Exchange Commission
July 11, 2019 Page 2 |
1. |
To the extent possible, please update all statistics and information to provide the most recent data.
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2. |
Please include a discussion of any material findings in the 2019 and 2018 reports on Italy issued by the European Commission.
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3. |
Please include discussion of recent elections in Italy, and clarify any related material effects on Italy’s recent policies, as well as any social,
economic or political effects.
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U.S. Securities and Exchange Commission
July 11, 2019 Page 3 |
4. |
Here or elsewhere, please provide a more detailed discussion of the various provisions of Law Decree No. 34 that was adopted on April 30, 2019. We note
references under “Public Finance” and “The 2018 Economic and Financial Document,” to the 2019 Stability Programme, 2019 National Reform Progamme, 2018 Stability Programme and 2018 National Reform Programme.
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5. |
Please include a more detailed discussion of any material impacts, including economic, social or political impacts, of the migrant and refugee
population.
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6. |
Please discuss any material economic effects in the European Union (“EU”) and Italy, if certain events were to occur, including: if a member country
were to abruptly leave the EU, further bailouts of EU countries, or another credit crisis. Include discussion of any material effects, including economic or political effects, in the EU and Italy, if the United Kingdom were to leave.
Please consider how those effects may vary depending on the terms of such departure.
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U.S. Securities and Exchange Commission
July 11, 2019 Page 4 |
7. |
Please update this section to reflect the recent election and any related material changes on the economic or political environment in the EU and
Italy. We note news reports of political, economic and currency issued between the EU and Italy.
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8. |
Please include discussion of any material effects the recession in the fourth quarter of 2018 had on Italy’s economy
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9. |
Please discuss the negotiations with the European Commission over the 2019 budget to expand the deficit over the limit allowed by the EU.
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U.S. Securities and Exchange Commission
July 11, 2019 Page 5 |
11. |
Please include a discussion of any material economic risks associated with Italy’s recently adopted measures, including the introduction of a basic
universal income, a flat tax rate and certain changes to the pension system.
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12. |
Here or elsewhere, if material, include disclosure of the recent Alitalia airline strike. Please include discussion of any material effects it may have
on Italy’s economy and recent debt refinancing.
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13. |
We note news reports of further capital issues with Banca Carige. Please update disclosure as necessary, and include a discussion of any material
risks.
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U.S. Securities and Exchange Commission
July 11, 2019 Page 6 |
14. |
In the tables, please identify the countries that are in the “other” category and, to the extent any country or region represents a material amount,
please separately identify them in the table.
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15. |
Please include a cross-reference to the section on page 34 describing Italy’s collective action clause.
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cc: |
Pranav L. Trivedi, Skadden, Arps, Slate, Meagher & Flom (UK) LLP
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