United States securities and exchange commission logo
November 8, 2023
Diego Rivas
Chief Financial Officer
Grupo Financiero Galicia SA
Tte. Gral. Juan D. Peron 430, 25th Floor
C1038 AAJ - Buenos Aires, Argentina
Re: Grupo Financiero
Galicia SA
Form 20-F Filed
April 24, 2023
Response Dated
November 1, 2023
File No. 000-30852
Dear Diego Rivas:
We have reviewed your November 1, 2023 response to our comment
letter and have the
following comments.
Please respond to this letter 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 a
comment applies to your facts and circumstances, please tell us why in
your response.
After reviewing your response to this letter, we may have
additional comments. Unless
we note otherwise, any references to prior comments are to comments in
our September 20,
2023 letter.
Form 20-F filed April 24, 2023
B.4 Selected Statistical Information
viii) Loss Experience, page 72
1. Please refer to prior
comment 1. Please tell us why you restated the opening balance of the
loan loss allowance
considering your statement that the loss allowance is a monetary item
and your disclosure on
page F-12, which is consistent with IAS 29.12, that monetary items
are not restated. Also,
tell us how you measured the restatement adjustment.
2. Please refer to prior
comment 1. In your response you state that the inflation effect also
represents movements
for the period. Please tell us in more detail what movements for
the period
represent, why they are presented as inflation effect , how the items are
measured and the
specific guidance in IFRS that supports the recognition.
Diego Rivas
Grupo Financiero Galicia SA
November 8, 2023
Page 2
Note 23 - Deposits, page F-51
3. Please refer to prior comment 3. Please provide us a draft of your
proposed disclosure in
future filings that includes the amount of uninsured deposits as of
December 31, 2022 and
December 31, 2021.
Please contact Shannon Davis at 202-551-6687 or Michael Volley at
202-551-3437 if you
have any questions.
Sincerely,
FirstName LastNameDiego Rivas
Division of
Corporation Finance
Comapany NameGrupo Financiero Galicia SA
Office of Finance
November 8, 2023 Page 2
cc: Enrique Pedemonte
FirstName LastName