SEC Company Response from CAMCO FINANCIAL CORP (CIK 0000016614) — Oct 25, 2005
CAMCO FINANCIAL CORP (CIK 0000016614)
Date: Oct. 25, 2005 · CIK: 0000016614 · Accession: 0000950152-05-008387
AI Filing Summary & Sentiment
File numbers found in text: 000-25196
Referenced dates: October 13, 2005
Letter
CAMCO FINANCIAL CORPORATION October 25, 2005 VIA EDGAR Ms. Joyce Sweeney, Accounting Branch Chief Securities and Exchange Commission Division of Corporation Finance Washington, D.C. 20549
Re: Camco Financial Corporation ("Camco") File No. 000-25196
Dear Ms. Sweeney:
The following information is provided in response to your comment letter dated October 13, 2005, pertaining to Form 10-K for the year ended December 31, 2004. The reply below responds to comments 1 and 2.
Item 9A. Controls and Procedures, page 75
During its year-end audit, Camco Financial Corporation ("Camco") was informed by its outside auditors that Camco was being more conservative than necessary by including in the FAS 114 evaluation loans that were less than 90 days delinquent, as was required by Camco's then current policy. Upon further review, Camco's auditors also noted that management should obtain third party appraisals for loans identified for evaluation under FAS 114 rather than rely solely upon internal evaluations. After discovery of this issue, management asked a third party to review and evaluate the potential FAS 114 loans in question.
The third party's review determined that some loans should not be evaluated under FAS 114 and should instead be evaluated through Camco's normal risk grading methodology procedures. However, this determination did not alter the total allowance for loan loss to be reported in Camco's financial statements. Rather, it merely recategorized portions of losses within the allowance for loan loss account. This change did not affect Camco's financial statements.
Therefore, when evaluating its disclosure controls and internal control over financial reporting, management determined that the issue did not affect Camco's disclosure controls because all of the allowance for loan loss that should be reported was fully and accurately reported in Camco's reports. The FAS 114 evaluation issue only concerned Camco's internal classification of the loan losses within the allowance for loan loss account. Thus, management determined that the issue only affected Camco's internal control over financial reporting.
<PAGE> Ms. Joyce Sweeney October 25, 2005 Page 2
By this letter, Camco acknowledges that: (1) it is responsible for the adequacy and accuracy of the disclosure in the filings; (2) staff comments or changes to disclosure in response to staff comments in the filings reviewed by the staff do not foreclose the Commission from taking any action with respect to the filing; and (3) Camco 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.
Please contact the undersigned at (740) 435-2055 with any questions you may have concerning the preceding response.
Very truly yours,
/s/ Mark A. Severson
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CAMCO FINANCIAL CORPORATION
October 25, 2005
VIA EDGAR
Ms. Joyce Sweeney, Accounting Branch Chief
Securities and Exchange Commission
Division of Corporation Finance
Washington, D.C. 20549
Re: Camco Financial Corporation ("Camco")
File No. 000-25196
Dear Ms. Sweeney:
The following information is provided in response to your comment letter
dated October 13, 2005, pertaining to Form 10-K for the year ended December 31,
2004. The reply below responds to comments 1 and 2.
Item 9A. Controls and Procedures, page 75
During its year-end audit, Camco Financial Corporation ("Camco") was
informed by its outside auditors that Camco was being more conservative
than necessary by including in the FAS 114 evaluation loans that were less
than 90 days delinquent, as was required by Camco's then current policy.
Upon further review, Camco's auditors also noted that management should
obtain third party appraisals for loans identified for evaluation under FAS
114 rather than rely solely upon internal evaluations. After discovery of
this issue, management asked a third party to review and evaluate the
potential FAS 114 loans in question.
The third party's review determined that some loans should not be
evaluated under FAS 114 and should instead be evaluated through Camco's
normal risk grading methodology procedures. However, this determination did
not alter the total allowance for loan loss to be reported in Camco's
financial statements. Rather, it merely recategorized portions of losses
within the allowance for loan loss account. This change did not affect
Camco's financial statements.
Therefore, when evaluating its disclosure controls and internal
control over financial reporting, management determined that the issue did
not affect Camco's disclosure controls because all of the allowance for
loan loss that should be reported was fully and accurately reported in
Camco's reports. The FAS 114 evaluation issue only concerned Camco's
internal classification of the loan losses within the allowance for loan
loss account. Thus, management determined that the issue only affected
Camco's internal control over financial reporting.
<PAGE>
Ms. Joyce Sweeney
October 25, 2005
Page 2
By this letter, Camco acknowledges that: (1) it is responsible for the
adequacy and accuracy of the disclosure in the filings; (2) staff comments or
changes to disclosure in response to staff comments in the filings reviewed by
the staff do not foreclose the Commission from taking any action with respect to
the filing; and (3) Camco 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.
Please contact the undersigned at (740) 435-2055 with any questions you may
have concerning the preceding response.
Very truly yours,
/s/ Mark A. Severson
Mark A. Severson
Chief Financial Officer
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