SEC Comment Letter for HUNTINGTON BANCSHARES (HBAN) — Nov 16, 2017
HUNTINGTON BANCSHARES INC /MD/ (HBAN, HBANL, HBANM, HBANP, HBANZ) (CIK 0000049196)
Date: Nov. 16, 2017 · CIK: 0000049196 · Accession: 0000000000-17-040659
AI Filing Summary & Sentiment
Reasoning
Letter
Mail Stop 4720 November 16, 2017 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, 2016 Filed February 22, 2017 Form 10 -Q for the Quarterly Period Ended September 30, 2017 Filed October 30, 2017 File No. 001 -34073
Dear Mr. McCullough III:
We have limited our review of your filing to the financial statements and related disclosures and have the following comments. In some of our comments, we may ask you to provide us with information so we may better understand your disclosure.
Please respond to these com ments 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 comments apply to your facts and circumstances, please tell us why in your response.
After reviewing your response to these comments, we may have additional comments.
Form 10 -K for the Fiscal Year Ended December 31, 2016
Note 4. Loans / Leases And Allowance For Credit Losses
Impaired Loans, page 128
1. Please reconcile the difference betwee n the portion of the allowance for loan and lease losses attributable to loans individually evaluated for impairment of $21,546 at December 31, 2016 on page 128 and the related allowance for loan and lease losses by class tables at December 31, 2016 on pag e 130. Please also reconcile the difference between the portion of the loan and lease ending balance attributable to purchase credit -impaired loans and attributable to loans individually evaluated for impairment of $975,894 at
Howell D. McCullough III Huntington Bancshares Incorporated November 16, 2017 Page 2
December 31, 2016 on page 12 8 and the total ending balance by class tables at December 31, 2016 on page 130. Please also tell us the reasons for these apparent differences and the impact, if any, on your financial statements. Please provide us with your materiality analysis under St aff Accounting Bulletin 99.
Form 10 -Q for the Quarterly Period Ended September 30, 2017
Note 3. Loans / Leases And Allowance For Credit Losses
Impaired Loans, page 55
2. Please reconcile the difference between the portion of the allowance for loan and lease losses attributable to loans individually evaluated for impairment of $36,712 at September 30, 2017 on page 55 and the related allowance for loan and lease losses by class tables at September 30, 2017 on page 56. Please also reconcile the difference between the portion of the loan and lease ending balance attributable to purchase credit - impaired loans and attributable to loans individually evaluated for impairment of $1,253,137 at September 30, 2017 on page 55 and the total ending balance by class ta bles at September 30, 2017 on page 56. Please also tell us the reasons for these apparent differences and the impact, if any, on your financial statements. Please provide us with your materiality analysis under Staff Accounting Bulletin 99.
We remind yo u that the company and its management are responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the staff.
You may contact Chris Harley at (202) 551 -3695 or me at (202) 551 -3752 with any questions.
Sincerely,
/s/ Gus Rodriguez
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Mail Stop 4720 November 16, 2017 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, 2016 Filed February 22, 2017 Form 10 -Q for the Quarterly Period Ended September 30, 2017 Filed October 30, 2017 File No. 001 -34073 Dear Mr. McCullough III: We have limited our review of your filing to the financial statements and related disclosures and have the following comments. In some of our comments, we may ask you to provide us with information so we may better understand your disclosure. Please respond to these com ments 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 comments apply to your facts and circumstances, please tell us why in your response. After reviewing your response to these comments, we may have additional comments. Form 10 -K for the Fiscal Year Ended December 31, 2016 Note 4. Loans / Leases And Allowance For Credit Losses Impaired Loans, page 128 1. Please reconcile the difference betwee n the portion of the allowance for loan and lease losses attributable to loans individually evaluated for impairment of $21,546 at December 31, 2016 on page 128 and the related allowance for loan and lease losses by class tables at December 31, 2016 on pag e 130. Please also reconcile the difference between the portion of the loan and lease ending balance attributable to purchase credit -impaired loans and attributable to loans individually evaluated for impairment of $975,894 at Howell D. McCullough III Huntington Bancshares Incorporated November 16, 2017 Page 2 December 31, 2016 on page 12 8 and the total ending balance by class tables at December 31, 2016 on page 130. Please also tell us the reasons for these apparent differences and the impact, if any, on your financial statements. Please provide us with your materiality analysis under St aff Accounting Bulletin 99. Form 10 -Q for the Quarterly Period Ended September 30, 2017 Note 3. Loans / Leases And Allowance For Credit Losses Impaired Loans, page 55 2. Please reconcile the difference between the portion of the allowance for loan and lease losses attributable to loans individually evaluated for impairment of $36,712 at September 30, 2017 on page 55 and the related allowance for loan and lease losses by class tables at September 30, 2017 on page 56. Please also reconcile the difference between the portion of the loan and lease ending balance attributable to purchase credit - impaired loans and attributable to loans individually evaluated for impairment of $1,253,137 at September 30, 2017 on page 55 and the total ending balance by class ta bles at September 30, 2017 on page 56. Please also tell us the reasons for these apparent differences and the impact, if any, on your financial statements. Please provide us with your materiality analysis under Staff Accounting Bulletin 99. We remind yo u that the company and its management are responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the staff. You may contact Chris Harley at (202) 551 -3695 or me at (202) 551 -3752 with any questions. Sincerely, /s/ Gus Rodriguez Gus Rodriguez Accounting Branch Chief Office of Financial Services