SEC Comment Letter for ASSOCIATED BANC-CORP (ASB, ASBA, ASB-PE, ASB-PF) (CIK 0000007789) (ASB) — Mar 19, 2015
ASSOCIATED BANC-CORP (ASB, ASBA, ASB-PE, ASB-PF) (CIK 0000007789)
Date: March 19, 2015 · CIK: 0000007789 · Accession: 0000000000-15-016406
AI Filing Summary & Sentiment
Reasoning
Letter
March 19, 2015 Via Email Christopher J. Del Moral -Niles Chief Financial Officer Associated Banc -Corp 433 Main Street Green Bay, Wisconsin 54301
Re: Associated Banc -Corp Form 10 -K for Fis cal Year Ended December 31 , 2014 Filed February 5, 2015 File No. 00 1-31343
Dear Mr. Del Moral -Niles :
We have reviewed your filing an d have the following comment . In our comment, we may ask you to provide us with information so we may better understand your disclosure.
Please respond to this letter within ten business days by amending your filing, by providing the requested information, or by advising us when you will provide the requested response. Where we have specifically requested a dra ft of your proposed disclosures in future filings, please ensure that it clearly identifies new, revised or deleted disclosures, as appropriate. If you do not believe our comment applies to your facts and circumstances or do not believe an amendment is ap propriate, please tell us why in your response.
After reviewing any amendment to your filing and the informati on you provide in response to th is comment , we may have additional comments.
Form 10 -K for the Fiscal Year Ended December 31, 2014
Notes to Consolidated Financial Statements Note 1 Summary of Significant Accounting Policies Troubled Debt Restructurings (“Restructured Loans”), page 81
1. We note your disclosure on page 81 that, in subsequent years, troubled debt restructurings may cease to be cla ssified as impaired. The guidance in ASC 310 -40-35 indicates that a loan restructured in a troubled debt restructuring is an impaired loan and therefore credit impairment should be measured using the guidance in ASC 310 -10. This guidance is applicable to all loans restructured in a troubled debt restructuring, even if you no longer classify the loan as a TDR. Please address how your accounting policy is in accordance with the accounting guidance as noted above.
Christopher J. Del Moral -Niles Associated Banc -Corp March 19 , 2015 Page 2
In responding to our comment , please provi de a written 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.
You may contact David Irving at (202) 551 -3321 or me at (202) 55 1-3452 if you any other questions.
Sincerely,
/s/ Marc Thomas
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March 19, 2015 Via Email Christopher J. Del Moral -Niles Chief Financial Officer Associated Banc -Corp 433 Main Street Green Bay, Wisconsin 54301 Re: Associated Banc -Corp Form 10 -K for Fis cal Year Ended December 31 , 2014 Filed February 5, 2015 File No. 00 1-31343 Dear Mr. Del Moral -Niles : We have reviewed your filing an d have the following comment . In our comment, we may ask you to provide us with information so we may better understand your disclosure. Please respond to this letter within ten business days by amending your filing, by providing the requested information, or by advising us when you will provide the requested response. Where we have specifically requested a dra ft of your proposed disclosures in future filings, please ensure that it clearly identifies new, revised or deleted disclosures, as appropriate. If you do not believe our comment applies to your facts and circumstances or do not believe an amendment is ap propriate, please tell us why in your response. After reviewing any amendment to your filing and the informati on you provide in response to th is comment , we may have additional comments. Form 10 -K for the Fiscal Year Ended December 31, 2014 Notes to Consolidated Financial Statements Note 1 Summary of Significant Accounting Policies Troubled Debt Restructurings (“Restructured Loans”), page 81 1. We note your disclosure on page 81 that, in subsequent years, troubled debt restructurings may cease to be cla ssified as impaired. The guidance in ASC 310 -40-35 indicates that a loan restructured in a troubled debt restructuring is an impaired loan and therefore credit impairment should be measured using the guidance in ASC 310 -10. This guidance is applicable to all loans restructured in a troubled debt restructuring, even if you no longer classify the loan as a TDR. Please address how your accounting policy is in accordance with the accounting guidance as noted above. Christopher J. Del Moral -Niles Associated Banc -Corp March 19 , 2015 Page 2 In responding to our comment , please provi de a written 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. You may contact David Irving at (202) 551 -3321 or me at (202) 55 1-3452 if you any other questions. Sincerely, /s/ Marc Thomas Marc Thomas Review Accountant