SEC – ‘UPLOAD’ from 10/20/23 re: European Investment Bank – ‘TEXT-EXTRACT’

On:  Friday, 10/20/23, at 5:36pm ET   ·   Delayed-Release:  Filing ¶  –  Release Delayed   ·   Accession #:  0-23-11516

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Comment or Other Letter from the SEC   —   Delayed-Release

Filing Table of Contents

Document/Exhibit                   Description                      Pages   Size 

 1: LETTER      Comment or Other Letter from the SEC                 PDF     42K 
 2: TEXT-EXTRACT  Comment or Other Letter from the SEC - PDF's         4±    14K 
                Text                                                             

‘TEXT-EXTRACT’   —   Comment or Other Letter from the SEC – PDF’s Text

United States securities and exchange commission logo                           

October 20, 2023      

Stavros Lambrinidis                                               
Ambassador                                                        
European Investment Bank                                          
98-100 boulevard Konrad Adenauer                                  
L-2950 Luxembourg                                                 
Grand Duchy of Luxembourg                                         

                                                       Re: European Investment
Bank                                                                            
                                                        Schedule B filed
September 26, 2023                                                              
                                                           File No. 333-274695

Dear Stavros Lambrinidis:                                         

                                                     We have reviewed your
registration statement and have the following comment(s).                       

       Please respond to this letter by amending your registration
statement and providing the                                                     
    requested information. If you do not believe a comment applies to your
facts and circumstances                                                         
  or do not believe an amendment is appropriate, please tell us why in
your response.                                                                  

            After reviewing any amendment to your registration statement and
the information you                                                             
  provide in response to this letter, we may have additional comments.

Schedule B filed September 26, 2023                               

The European Investment Bank, page 8                              

1.                                                   The annual reports   
incorporated by reference provide detailed disclosure about not only            
                                                       the European Investment
Bank (EIB) but also the European Investment Fund (EIF), which                   
                                               are referred to
collectively in your annual reports as the EIB Group. While your                
                                                    prospectus describes
EIB Global, it does not discuss the EIF or EIB Group. Please revise             
                                                      your filing to clarify
the roles of the EIF and EIB Group.                                             
Description of Securities,, page 14                               

2.                                                   You state that       
"[c]opies of the forms of securities and the form of fiscal agency agreement    
                                                     are filed as exhibits
to the registration statement of which this prospectus forms a part.            
                                                     This summary does not
purport to be complete and is qualified in its entirety by reference            
                                                      to those exhibits. For
a complete description of those securities, you should read those               
                                                 exhibits." We are
unable to locate the form of securities. Please advise or revise.               
Stavros Lambrinidis                                                           
FirstName LastNameStavros                                                       
European Investment Bank Lambrinidis                                            
Comapany                                                                        
October 20,NameEuropean                                                         
2023        Investment Bank                             
October                                                                         
Page 2 20, 2023 Page 2                                                          
FirstName LastName                                                              
3.       We refer you to the "Amendments" disclosure on page 17. Please advise  
as to whether                                                                   
  any of the changes requiring majority approval may relate to the
repayment terms of the                                                          
 securities, similar to the changes requiring unanimous approval
disclosed on page 18.                                                           

Foreign Exchange Risks, page 28                                                 

4.       You discuss foreign exchange risks and state that "[f]or additional    
information regarding                                                           
     exchange rates, see Exhibit I of the EIB   s Annual Reports on Form
18K incorporated                                                                
      herein by reference." Please provide a more specific cross-reference
so readers can locate                                                           
the specific risk disclosures within the EIB's Annual Reports.
Taxation, page 28                                                               

5.       You state that    [i]t is the opinion of counsel, Cravath, Swaine &    
Moore LLP, that the                                                             
        conclusions reached in this section describe the material U.S. Federal
tax consequences to                                                             
       holders of a security.    Please clarify whether or not there are any
material foreign tax                                                            
       consequences and if so, please revise your filing accordingly. Please
see Staff Legal                                                                 
      Bulletin 19 (Oct. 14, 2011) at Section III, footnote 40 and footnote
42.                                                                             

Form 18-K filed May 5, 2023                                                     
General, page 29                                                                

6.       You state on page 29 of the 2022 Financial Report that    [t]he EIB    
s Group   s consolidated                                                        
       result under the International Reporting Standards (IFRS) amounted to
EUR 2 327.0                                                                     
million in 2022 as compared to EUR 8 277.3 million in 2021,   
representing a decrease of                                                      
       EUR 5 950.3 million year on year, or 71.9%.    The text corresponding
to and footnote 7 in                                                            
      Note M of the EIB Group Consolidated Financial Statements under IFRS
provides that                                                                   
     this change is largely driven by the net result on shares and other
variable yield securities                                                       
  and the negative valuation effects observed in    private equity
markets during 2022.    We                                                      
       also note the significant variance in your consolidated results under
IFRS as disclosed on                                                            
     page 32 of your 2021 Financial Report where you state    [t]he 2021
IFRS consolidated                                                               
       result stands at EUR 8 277.3 million as compared to a result of EUR 2
637.4 million                                                                   
     observed in 2020 (an increase of EUR 5 639.9 million year on year).
Please discuss                                                                  
  those private equity investments that are individually or in the
aggregate material and                                                          
drove these significant variations in 2022 and 2021.          

Note R Fair Value of Financial Assets and Liabilities, page 232                 

7.       We note your disclosure on page 198 that private equity, venture       
capital operations, debt                                                        
      infrastructure and investment funds are measured mandatorily at fair
value through profit                                                            
or loss with changes in the fair value recorded in Results on 
Financial Operations. We                                                        
      note from your disclosure on page 232 that you have classified these
investments as Level                                                            
    3 in the fair value hierarchy as part of shares and other variable
yield securities, but we                                                        
Stavros Lambrinidis                                                           
European Investment Bank                                                        
October 20, 2023                                                                
Page 3                                                                          
    were unable to locate the disclosures required by IFRS13.93(d) and
IFRS 13.93(h). Please                                                           
       supplementally provide us with this information or tell us why you do
not believe these                                                               
disclosures are required.                                     
     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.                                                            

    Refer to Rules 460 and 461 regarding requests for acceleration. Please
allow adequate                                                                  
time for us to review any amendment prior to the requested effective date of    
the registration                                                                
statement.                                                                      

      Please contact Angie Kim at 202-551-3535 or Michael Coco at 202-551-3253
with any                                                                        
other questions.                                                                

                                                  Sincerely,
FirstName LastNameStavros Lambrinidis                                           
                                                   Division of
Corporation Finance                                                             
Comapany NameEuropean Investment Bank                                           
                                                 Office of
International Corporate                                                         
October 20, 2023 Page 3                                     Finance             
FirstName LastName                                                              

Dates Referenced Herein   and   Documents Incorporated by Reference

This ‘UPLOAD’ Filing		Date		Other Filings
Filed on:		10/20/23		UPLOAD
		9/26/23		S-B,  UPLOAD
		5/5/23		18-K,  UPLOAD
		10/14/11		UPLOAD
				List all Filings

1 Previous Filing that this Filing References

  As Of               Filer                 Filing    For·On·As Docs:Size             Issuer                      Filing Agent

 9/26/23  European Investment Bank          S-B                    7:3.3M                                   Cravath Swaine & … 01/FA