United States securities and exchange commission logo
September 20, 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
File No. 000-30852
Dear Diego Rivas:
We have limited our review of your filing to the financial
statements and related
disclosures 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.
Form 20-F filed April 24, 2023
B.4 Selected Statistical Information
viii) Loss Experience, page 72
1. We note the material
adjustments in the changes in the loss allowance tables on page 72
presented as
Inflation effect . Please provide us an accounting analysis detailing what
these adjustments
represent, the specific IFRS guidance that supports the adjustments,
where the offsetting
amounts are recognized, and how the adjustments were measured.
Specifically tell us if
the loss allowance is a monetary item under IAS 29 and whether the
adjustments represent
the restatement of the opening balances. Please revise future filings
to explain more clearly
what this adjustment represents and provide additional information
in your accounting
policies to explain why it was recognized.
2. Please tell us and
revise future filings to disclose whether your financial statements are
based on a historical
cost approach or a current cost approach. Refer to IAS 29.39(b) for
Diego Rivas
Grupo Financiero Galicia SA
September 20, 2023
Page 2
guidance.
Note 23 - Deposits, page F-51
3. Please tell us and revise future filings to disclose the information
required by Item 1406(e)
of Regulation S-K.
In closing, 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 Shannon Davis at (202) 551-6687 or Michael Volley at
(202) 551-
3437 with any questions.
FirstName LastNameDiego Rivas Sincerely,
Comapany NameGrupo Financiero Galicia SA
Division of
Corporation Finance
September 20, 2023 Page 2 Office of
Finance
FirstName LastName