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SEC Company Response from INDEPENDENT BANK (IBCP) — Aug 25, 2009

INDEPENDENT BANK CORP /MI/ (IBCP) (CIK 0000039311)
Date: Aug. 25, 2009 · CIK: 0000039311 · Accession: 0000926044-09-000468

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File numbers found in text: 000-07818

Date
August 24, 2009
Author
/s/ Robert N. Shuster
Form
CORRESP
Company
INDEPENDENT BANK CORP /MI/ (IBCP) (CIK 0000039311)

Letter

BY EDGAR August 24, 2009 Amit Pande, Accounting Branch Chief Edwin Adames, Senior Staff Accountant Securities and Exchange Commission Washington, D.C. 20549

Re: Independent Bank Corporation – File No. 000-07818

Dear Mr. Pande and Mr. Adames,

We are in receipt of the comment letter from the Securities and Exchange Commission (“SEC”) dated August 19, 2009 (the “Comment Letter”). The Comment Letter requests a response within 10 business days or “tell us when you will provide us with a response.” We would like to request an extension for our response to Monday, September 21, 2009 (i.e. approximately 30 days). We request this extension for the following reasons:

•

The response time period falls over the Labor Day holiday, with vacation schedules, our proposed September 21st date, will assist us in managing existing workloads for the personnel needed to respond to the Comment Letter;

•

There are a number of requests in the Comment Letter for additional information on technical areas, such as the method and assumptions utilized for determining the fair value of securities. The additional time will allow us to more thoroughly respond to your request; and

•

The September 21st date provides us with additional time to work with our independent registered public accounting firm for those topics in which we will be seeking their feedback.

Please let us know by contacting the undersigned at 616-522-1765 or by e-mail at rshuster@ibcp.com if our proposed response date of September 21, 2009 is acceptable.

Thank you for your consideration.

Sincerely,
/s/ Robert N. Shuster

Show Raw Text
CORRESP
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filename1.htm

BY EDGAR

August 24, 2009

Amit Pande, Accounting
Branch Chief
Edwin Adames, Senior Staff Accountant
Securities and Exchange
Commission
Washington, D.C. 20549

Re:
Independent
Bank Corporation – File No. 000-07818

Dear Mr. Pande and Mr.
Adames,

We are in receipt of the comment
letter from the Securities and Exchange Commission (“SEC”) dated August 19, 2009
(the “Comment Letter”). The Comment Letter requests a response within 10
business days or “tell us when you will provide us with a response.” We would
like to request an extension for our response to Monday, September 21, 2009 (i.e.
approximately 30 days). We request this extension for the following reasons:

•

The response time period falls over the Labor Day holiday, with vacation schedules, our
proposed September 21st date, will assist us in managing existing workloads for
the personnel needed to respond to the Comment Letter;

•

There are a number of requests in the Comment Letter for additional information on
technical areas, such as the method and assumptions utilized for determining the fair
value of securities. The additional time will allow us to more thoroughly respond to your
request; and

•

The September 21st date provides us with additional time to work with our
independent registered public accounting firm for those topics in which we will be seeking
their feedback.

Please let us know by contacting the
undersigned at 616-522-1765 or by e-mail at rshuster@ibcp.com if our proposed
response date of September 21, 2009 is acceptable.

Thank you for your consideration.

Sincerely,

/s/ Robert N. Shuster

Robert N. Shuster
Executive Vice President
and Chief Financial Officer

230 West Main Street,
Ionia, MI 48846