<DOCUMENT>
<TYPE>TEXT-EXTRACT
<SEQUENCE>2
<FILENAME>filename2.txt
<TEXT>
                                                             June 4, 2019

Michela Casassa Ramat
Chief Financial Officer
Intercorp Financial Services Inc.
Av. Carlos Villar n 140
Urbanizaci n Santa Catalina
La Victoria
Lima 13, Peru

       Re: Intercorp Financial Services Inc.
           Draft Registration Statement on Form F-1
           Submitted May 8, 2019
           CIK No. 0001615903

Dear Ms. Casassa Ramat:

       We have reviewed your draft registration statement 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 this letter by providing the requested information and
either submitting
an amended draft registration statement or publicly filing your registration
statement on
EDGAR. If you do not believe our comments apply to your facts and circumstances
or do not
believe an amendment is appropriate, please tell us why in your response.

      After reviewing the information you provide in response to these comments
and your
amended draft registration statement or filed registration statement, we may
have additional
comments.

Draft Registration Statement on Form F-1

Management's Discussion and Analysis of Results of Operations and Financial
Condition
Results of Operations for the Year Ended December 31, 2018 Compared to Year
Ended
December 31, 2017, page 75

1.     Please revise to discuss changes in financial condition for the periods
presented. Please
       refer to Item 303 of Regulation S-K.
 Michela Casassa Ramat
FirstName LastNameMichela Casassa Ramat
Intercorp Financial Services Inc.
Comapany NameIntercorp Financial Services Inc.
June 4, 2019
June 4, 2019 Page 2
Page 2
FirstName LastName
Results of Operations by Segment, page 77

2.       We note that total net premiums earned minus claims and benefits
increased S/254.5
         million and 167% in 2018 primarily due to increases in net claims and
benefits offset by
         increases in net premiums due to the acquisition of Seguros Sura.
Please enhance your
         disclosure to clarify why the increase in net claims and benefits was
significantly greater
         than the increase in net premiums and if you expect this trend to
continue.
Selected Statistical Information
Loan Portfolio, page 122

3.       Please disclose foreign loans by country where such borrowings exceed
1% of total assets
         or disclose that you do not have any such exposure. Refer to Guide 3;
Item 3.C.
Composition of Deposits and Other Commitments, page 129

4.       Please disclose deposits in foreign banking offices, material deposits
by foreign
         depositors, time deposits in amount of $100,000 or more by maturity
both domestically
         and in foreign offices. Refer to Guide 3; Item 5.
Business
Wealth Management Segment
Portfolio Investments, page 192

5.       Please disaggregate your assets under management by asset class type,
e.g. equity, fixed
         income, etc.
Banking Segment
Market Risk, page 206

6.       You state on pages 207, 210 and 213, that for Interbank, Interseguro
and Inteligo you
         utilize Value-at-risk (VaR) to assess market risk. Please address the
following:

             Disclose the VaR results for Interbank, Interseguro and Inteligo
for the periods
             presented and discuss material year-over-year changes; and
             Disclose if you had any back-testing exceptions for the periods
presented.
Principal Shareholders, page 246

7.       Please revise your table to reflect the number of shares beneficially
owned by Intercorp
         Per  Ltd as that term is defined by General Instruction F of Form
20-F. In this regard we
         note your disclosure on page 254 that Intercorp Peru Ltd. holds 57.08%
of your common
         shares directly, and 17.24% indirectly through its subsidiaries
Intercorp Capital
         Investments Inc. and IFH Capital Corp.
 Michela Casassa Ramat
Intercorp Financial Services Inc.
June 4, 2019
Page 3
8.       We note your disclosure in footnote (1) that the selling shareholders,
IFH Capital Corp.
         and Intercorp Capital Investments Inc., are "owned and controlled by
the Rodriguez Pastor
         family." Please disclose, if true, that Mr. Carlos Rodriguez Pastor
Persivale is the sole
         "beneficial owner" of the shares offered by the selling shareholders
or revise to disclose
         "any person" that is the beneficial owner of the shares offered by the
selling shareholders.
         Please make conforming revisions with respect to the beneficial
ownership of the 57.1%
         of your shares held directly by Intercorp Per  Ltd.'s, naming the
"natural or legal
         person(s)" that beneficially own these shares, or provide us with your
detailed legal
         analysis for why this information is not material. Please refer to
General Instruction E,
         Item 7.A.3, and Item 9.D of Form 20-F for guidance.
9.       We note that the underwriters have the option to purchase additional
common shares
         from each of you, Interbank and the selling shareholders, and that
your beneficial
         ownership disclosure after the offering assumes the underwriters do
not exercise
         their option to purchase additional common shares. Please revise to
also disclose your
         beneficial ownership disclosure after the offering, by footnote or
otherwise, in the event
         that the underwriters do exercise this option. Please refer to Item
9.D.2 of Form 20-F for
         guidance.
Consolidated Financial Statements
Notes to the consolidated financial statements
Note 7. Loans, net, page F-81

10.      Please disaggregate the following disclosures by portfolio class, e.g.
commercial,
         consumer, etc:

             Credit quality and maximum exposure to credit risk based on your
internal credit
             rating as presented on page F-82;
             The movement of the allowance for expected credit losses
calculated according
             to IFRS 9 as presented on page F-83; and
             Past due and under legal collection loans as presented on page
F-86.

         Refer to IFRS 7.35(B) and (F) and 7.B.8.
Note 13. Due to banks and correspondents, page F-99

11.    We note from your discussion of outstanding indebtedness of Interbank
beginning on page
       102, that certain of your loan and credit facilities contain covenants.
We also note from
       your disclosure on page F-101, that some of your bank loan agreements
include standard
FirstName LastNameMichela Casassa Ramat
       clauses regarding compliance of financial ratios, the use of funds, and
other management
Comapany NameIntercorp Financial Services Inc.
       issues. Please enhance your disclosure to clarify whether the Group was
in compliance
June 4,with all of the covenants for the periods presented.
        2019 Page 3
FirstName LastName
 Michela Casassa Ramat
FirstName LastNameMichela Casassa Ramat
Intercorp Financial Services Inc.
Comapany NameIntercorp Financial Services Inc.
June 4, 2019
Page 4
June 4, 2019 Page 4
FirstName LastName
       You may contact Michelle Miller, Staff Accountant, at (202) 551-3368 or
Gus
Rodriguez, Accounting Branch Chief, at (202) 551-3752 if you have questions
regarding
comments on the financial statements and related matters. Please contact
Christopher Dunham,
Staff Attorney, at (202) 551-3783 or Erin Purnell, Staff Attorney, at (202)
551-3454 with any
other questions.



                                                          Sincerely,

                                                          Division of
Corporation Finance
                                                          Office of Financial
Services
cc:      Antonia E. Stolper, Esq.
</TEXT>
</DOCUMENT>
