SEC Comment Letter for ASSOCIATED BANC-CORP (ASB, ASBA, ASB-PE, ASB-PF) (CIK 0000007789) (ASB) — Mar 21, 2007
ASSOCIATED BANC-CORP (ASB, ASBA, ASB-PE, ASB-PF) (CIK 0000007789)
Date: March 21, 2007 · CIK: 0000007789 · Accession: 0000000000-07-014461
AI Filing Summary & Sentiment
Reasoning
Letter
Mail Stop 4561 March 21, 2007 Mr. Paul S. Beideman Chairman and Chief Executive Officer Associated Banc-Corp 1200 Hansen Road Green Bay, Wisconsin 54304
Re: Associated Banc-Corp Form 10-K for Fiscal Year Ended December 31, 2006
Dear Mr. Beideman:
We have reviewed the above referenced filings and have the following comment. We have limited our review to only your fina ncial statements and related disclosures and do not intend to expand our review to other portions of your documents. In our comment, we ask you to provide us with information so we may better understand your disclosure. After reviewing this information, we may raise additional comments.
Please understand that the purpose of our re view process is to assist you in your compliance with the applicable disclosure requirements and to enhance the overall disclosure in your filing. We look forward to working with you in these respects. We welcome any questions you may have about our comments or any other aspect of our review. Feel free to call us at the telephone numbers listed at the end of this letter.
Form 10-K for the Fiscal Year Ended December 31, 2006
Note 10 – Stockholders’ Equity, page 89
1. It appears you have included the SFA S 158 transition adjustment required by paragraph 16(a) of SFAS 158 in Other Co mprehensive Income. Please tell us how the inclusion of the transition adju stment in Other Comprehensive Income complies with paragraph A7 of SFAS 158.
* * *
Mr. Paul S. Beideman Associated Banc-Corp March 21, 2007 Page 2
As appropriate, please respond to this comm ent within 10 business days or tell us when you will provide us with a response. Please furnish a cover letter with your response that keys your responses to our comment and provides the requested information. Detailed cover le tters greatly facilitate our re view. Please understand that we may have additional comments after re viewing your responses to our comment.
We urge all persons who are responsi ble for the accuracy an d adequacy of the disclosure in the filing to be certain that the filing includes all in formation required under the Securities Exchange Act of 1934 and th at they have provided all information investors require for an informed invest ment decision. Since the company and its management are in possession of all facts re lating to a company’s disclosure, they are responsible for the accuracy and adequacy of the disclosures they have made.
In connection with responding to our comments, please provide, in writing, a statement from the company acknowledging that:
the company is responsible for the adequacy and accuracy of the disclosure in the filing;
staff comments or changes to disclosure in response to staff comments do not foreclose the Commission from taking any action with respect to the filing; and
the company may not assert staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.
In addition, please be advise d that the Division of Enfo rcement has access to all information you provide to the staff of the Divi sion of Corporation Fi nance in our review of your filing or in response to our comment on your filing.
You may contact Matthew Komar, Staff Accountant, at (202) 551-3781 or me at (202) 551-3851, if you have questions regardi ng the comment on the financial statements and related matters.
Sincerely,
Paul Cline
S e n i o r A c c o u n t a n t
Show Raw Text
Mail Stop 4561
March 21, 2007
Mr. Paul S. Beideman
Chairman and Chief Executive Officer
Associated Banc-Corp
1200 Hansen Road
Green Bay, Wisconsin 54304
Re: Associated Banc-Corp
Form 10-K for Fiscal Year Ended December 31, 2006
Dear Mr. Beideman:
We have reviewed the above referenced filings and have the following comment.
We have limited our review to only your fina ncial statements and related disclosures and
do not intend to expand our review to other portions of your documents. In our comment,
we ask you to provide us with information so we may better understand your disclosure.
After reviewing this information, we may raise additional comments.
Please understand that the purpose of our re view process is to assist you in your
compliance with the applicable disclosure requirements and to enhance the overall
disclosure in your filing. We look forward to working with you in these respects. We
welcome any questions you may have about our comments or any other aspect of our
review. Feel free to call us at the telephone numbers listed at the end of this letter.
Form 10-K for the Fiscal Year Ended December 31, 2006
Note 10 – Stockholders’ Equity, page 89
1. It appears you have included the SFA S 158 transition adjustment required by
paragraph 16(a) of SFAS 158 in Other Co mprehensive Income. Please tell us
how the inclusion of the transition adju stment in Other Comprehensive Income
complies with paragraph A7 of SFAS 158.
* * *
Mr. Paul S. Beideman
Associated Banc-Corp
March 21, 2007 Page 2
As appropriate, please respond to this comm ent within 10 business days or tell us
when you will provide us with a response. Please furnish a cover letter with your
response that keys your responses to our comment and provides the requested
information. Detailed cover le tters greatly facilitate our re view. Please understand that
we may have additional comments after re viewing your responses to our comment.
We urge all persons who are responsi ble for the accuracy an d adequacy of the
disclosure in the filing to be certain that the filing includes all in formation required under
the Securities Exchange Act of 1934 and th at they have provided all information
investors require for an informed invest ment decision. Since the company and its
management are in possession of all facts re lating to a company’s disclosure, they are
responsible for the accuracy and adequacy of the disclosures they have made.
In connection with responding to our comments, please provide, in writing, a statement from the company acknowledging that:
the company is responsible for the adequacy and accuracy of the disclosure in the
filing;
staff comments or changes to disclosure in response to staff comments do not
foreclose the Commission from taking any action with respect to the filing; and
the company may not assert staff comments as a defense in any proceeding initiated
by the Commission or any person under the federal securities laws of the United States.
In addition, please be advise d that the Division of Enfo rcement has access to all
information you provide to the staff of the Divi sion of Corporation Fi nance in our review
of your filing or in response to our comment on your filing.
You may contact Matthew Komar, Staff Accountant, at (202) 551-3781 or me at
(202) 551-3851, if you have questions regardi ng the comment on the financial statements
and related matters.
Sincerely,
Paul Cline
S e n i o r A c c o u n t a n t