Tender Offers for Compagnie Maritime Belge NV

Form Type: CORRESP

Filing Date: 2024-10-31

Corporate Action: Tender-offer

Type: Update

Accession Number: 000119312524248386

Comments: Compagnie Maritime Belge NV (CMB) submitted a response to a comment letter from the U.S. Securities and Exchange Commission regarding its Tender Offer Statement on Schedule TO, filed on October 23, 2024. The document addresses concerns about the offer price of $12.66 for each Ordinary Share, which may be reduced by any company distributions occurring before the settlement date. CMB indicated that the period between the expiration date of the offer (November 21, 2024) and the settlement date (November 27, 2024) is too short to declare a dividend before the settlement. CMB confirmed it does not intend to declare any dividend prior to the settlement date of the Offers, ensuring compliance with SEC rules. The structure of the Offers is believed to meet SEC obligations, particularly Rule 14e-1(b). Additionally, CMB will extend the Offers if there is a material change in terms, including any reduction in the Offer Price.

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