SEC Comment Letter for HUNTINGTON BANCSHARES (HBAN) — Dec 14, 2015
HUNTINGTON BANCSHARES INC /MD/ (HBAN, HBANL, HBANM, HBANP, HBANZ) (CIK 0000049196)
Date: Dec. 14, 2015 · CIK: 0000049196 · Accession: 0000000000-15-057743
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 001-34073
Letter
Mail Stop 4720 December 14, 2015 Via E -mail Howell D. McCullough III Chief Financial Officer Huntington Bancshares Incorporated 41 South High Street Columbus, Ohio 43287
Re: Huntington Bancshares Incorporated Form 10-K for the fiscal year ended December 31, 2014 Filed February 13, 2015 Form 10 -Q for the quarterly period ended September 30, 2015 Filed October 30, 2015 File No. 001-34073
Dear Mr. McCullough :
We have limited our review of your filing s to the financial statements and related disclosures and have the following comment .
Please respond to the comment within ten busine ss days by providing the requested information or advis e us as soon as possible when you will respond. If you do not believe our comment applies to your facts and circumstances, please tell us why in your response.
After reviewing your response to the comment , we may have additional comments.
Form 10 -Q for the period ended September 30, 2015
Exhibits 32.1 and 32.2
1. We note that your 906 certifications reference the quarterly report for the period en ding June 30, 2015 instead of the quarterly report for the period ending September 30, 2015. Please amend your Form 10 -Q for the period ended September 30, 2015 accordingly.
We urge all persons who are responsible for the accuracy and adequacy of the d isclosure in the filing to be certain that the filing includes the information the Securities Exchange Act of 1934 and all applicable Exchange Act rules require. Since the company and its management are
Howell D. McCullough III Huntington Bancshares Incorporated December 14, 2015 Page 2
in possession of all facts relating to a company’s d isclosure, they are responsible for the accuracy and adequacy of the disclosures they have made.
In responding to our comments, please provide 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 Michael Henderson , Staff Accountant, at (202) 551 -3364 or Yolanda R. Trotter , Staff Accountant, at (202) 551 -3472 , or me at (202) 551 -3494 with any questions.
Sincerely,
/s/ Kevin W. Vaughn
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Mail Stop 4720 December 14, 2015 Via E -mail Howell D. McCullough III Chief Financial Officer Huntington Bancshares Incorporated 41 South High Street Columbus, Ohio 43287 Re: Huntington Bancshares Incorporated Form 10-K for the fiscal year ended December 31, 2014 Filed February 13, 2015 Form 10 -Q for the quarterly period ended September 30, 2015 Filed October 30, 2015 File No. 001-34073 Dear Mr. McCullough : We have limited our review of your filing s to the financial statements and related disclosures and have the following comment . Please respond to the comment within ten busine ss days by providing the requested information or advis e us as soon as possible when you will respond. If you do not believe our comment applies to your facts and circumstances, please tell us why in your response. After reviewing your response to the comment , we may have additional comments. Form 10 -Q for the period ended September 30, 2015 Exhibits 32.1 and 32.2 1. We note that your 906 certifications reference the quarterly report for the period en ding June 30, 2015 instead of the quarterly report for the period ending September 30, 2015. Please amend your Form 10 -Q for the period ended September 30, 2015 accordingly. We urge all persons who are responsible for the accuracy and adequacy of the d isclosure in the filing to be certain that the filing includes the information the Securities Exchange Act of 1934 and all applicable Exchange Act rules require. Since the company and its management are Howell D. McCullough III Huntington Bancshares Incorporated December 14, 2015 Page 2 in possession of all facts relating to a company’s d isclosure, they are responsible for the accuracy and adequacy of the disclosures they have made. In responding to our comments, please provide 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 Michael Henderson , Staff Accountant, at (202) 551 -3364 or Yolanda R. Trotter , Staff Accountant, at (202) 551 -3472 , or me at (202) 551 -3494 with any questions. Sincerely, /s/ Kevin W. Vaughn Kevin W. Vaughn Branch Chief Office of Financial Services