September 5, 2025
VIA EDGAR
U.S. Securities and Exchange Commission
Division of Corporation Finance
Office of Finance
100 F Street, N.E.
Washington, D.C. 20549-3628
| Attn: | Mr. Shane Callaghan |
Mr. Todd Schiffman
Mr. Christian Windsor
| Re: | Banco Bilbao Vizcaya Argentaria, S.A. |
Registration Statement on Form F-4, as amended
File No. 333-281111
Ladies and Gentlemen:
With respect to the above-referenced registration statement (the “Registration Statement”) of Banco Bilbao Vizcaya Argentaria, S.A. (the “Registrant”), and pursuant to Rule 461 of Regulation C promulgated under the Securities Act of 1933, as amended, we hereby respectfully request that the Securities and Exchange Commission accelerate the effective date of the Registration Statement so that it is declared effective at 5:30 p.m. (EST) on September 8, 2025 or as soon as practicable thereafter.
Please contact Michael J. Willisch of Davis Polk & Wardwell LLP, counsel to the Registrant, at +(34) 91 768 9610, as soon as the Registration Statement has been declared effective, or if you have any other questions or concerns regarding this matter.
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