United States securities and exchange commission logo
March 10, 2023
Dixit Joshi
Chief Financial Officer
Credit Suisse AG
Paradeplatz 8
8001 Zurich, Switzerland
Re: Credit Suisse AG
Form 20-F for the
Fiscal Year Ended December 31, 2021
Response Dated
February 13, 2023
File No. 001-33434
Dear Dixit Joshi:
We have reviewed your February 13, 2023 response to our comment
letter and have the
following comments. In some of our comments, we may ask you to provide
us with information
so we may better understand your disclosure.
Please respond to these comments 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
comments apply to your facts and circumstances, please tell us why in
your response.
After reviewing your response to these comments, we may have
additional
comments. Unless we note otherwise, our references to prior comments are
to comments in our
January 17, 2023 letter.
Form 20-F for the Fiscal Year Ended December 31, 2021
Notes to the Consolidated Financial Statements
Note 1 - Summary of Significant Accounting Policies
Revisions of prior period financial statements, page 466
1. We have reviewed the
response you provided on February 13, 2023 in response to our
comment letter dated
January 17, 2023. We also have considered the discussions on
March 8-10, 2023 with
the Company and would like to better understand how you
concluded that a
broader risk assessment entity-level control material weakness did not
exist as of December
31, 2022 and 2021. Please respond to the following:
We note in the
root cause analysis you provided, you concluded the two cash flow
control
deficiencies resulted from missing controls designed to address the risks of
Dixit Joshi
FirstName LastNameDixit Joshi
Credit Suisse AG
Comapany
March NameCredit Suisse AG
10, 2023
March2 10, 2023 Page 2
Page
FirstName LastName
presentation and disclosure to the financial statements. While
you concluded that one
control deficiency was remediated as of December 31, 2021, it
does not appear that
either control deficiency was linked to risk assessment. In light
of the fact that there
were indications of missing controls responsive to risks of
material misstatements,
explain how you believe there was not a failure in the risk
assessment entity-level
control component as of December 31, 2022 and 2021.
Given that the control deficiencies remained unremediated for
several years,
including periods prior to those presented in the December 31,
2021 Form 20-F, tell
us how you concluded that this also was not indicative of
potential risk assessment
failures.
2. We have reviewed the response you provided on February 13, 2023 in
response to our
comment letter dated January 17, 2023. We also have considered the
discussions on
March 8-10, 2023 with the Company and would like to better understand
how you
concluded that a broader monitoring entity-level control material
weakness did not exist
as of December 31, 2022 and 2021. For the unremediated control
deficiencies, the
following items remain unclear as to how you arrived at the
conclusions in your analysis:
why you consider the fact that the related transactions were
limited, non-core, unique,
and/or immaterial to be persuasive support for your conclusions,
given the nature of
the transactions and the company s underlying business
operations;
how your control deficiency evaluation considered the impact of
the restatement of
previously issued financial statements to reflect the correction
of the error;
whether you considered the impacts of the magnitude of the
potential error for 2019
through 2021 related to not only the individual line items but
also the total operating,
investing, and financing cash flows in reaching your conclusions,
given that you
identify these subtotals as important to users of the financial
statements; and
when you completed the quantitative analysis of the potential
magnitude, and
whether it was complete at the time of the initial severity
assessment or if you
subsequently determined that a supplementary analysis was
required.
Please tell us how you considered whether the impact of the potential
error indicated any
unidentified material weakness(es), including any with the monitoring
entity-level control
component related to principle 17 of the Committee of Sponsoring
Organization of the
Treadway Commission (COSO) Internal Control Integrated Framework
(2013).
3. Please confirm that you have reassessed the root cause and severity
for each unremediated
control deficiency existing as of December 31, 2022 and their
resulting impact to the risk
assessment or monitoring entity-level components.
Dixit Joshi
Credit Suisse AG
March 10, 2023
Page 3
You may contact Cara Lubit at 202-551-5909 or Robert Klein at
202-551-3847 if you
have questions regarding comments on the financial statements and related
matters.
Sincerely,
FirstName LastNameDixit Joshi
Division of Corporation
Finance
Comapany NameCredit Suisse AG
Office of Finance
March 10, 2023 Page 3
cc: Sebastian Sperber
FirstName LastName