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SEC Comment Letter for MERCANTILE BANKSHARES CORP (CIK 0000064908) — Dec 23, 2005

MERCANTILE BANKSHARES CORP (CIK 0000064908)
Date: Dec. 23, 2005 · CIK: 0000064908 · Accession: 0000000000-05-063752

AI Filing Summary & Sentiment

Referenced dates: December 9, 2005, November 17, 2005

Date
December 22, 2005
Author
John P. Nolan
Form
UPLOAD
Company
MERCANTILE BANKSHARES CORP (CIK 0000064908)

Letter

Mail Stop 4561 By U.S. Mail and facsimile to (410)237-5427 Mr. Edward J. Kelly, III President and Chief Executive Officer Mercantile Bankshares Corporation Two Hopkins Plaza P.O. Box 1477 Baltimore, MD 21203

Re: Mercantile Bankshares Corporation Form 10-K for the Fiscal Year Ended December 31, 2004 Filed March 15, 2005 File No. 0-5127

Dear Mr. Kelly:

We have reviewed your response letter dated December 9, 2005 and have the following additional comment.

Form 10-K, filed on March 15, 2005

Management`s Discussion and Analysis of Financial Condition and Results of Operations

Non-GAAP Reconciliation, page 54 1. We note your response to comments 2 and 3 in our letter dated November 17, 2005 regarding the useful information for investors provided by the inclusion of non-GAAP financial measures. Please provide us with the proposed additional disclosures you will use in your 12/31/2005 financial statements to disclose the reasons management believes that presentation of these non-GAAP financial measures provides useful information to investors. Please refer to Item 10(e)(i)(C) of Regulation S-K.

* * * * *

Please respond to this comment within 10 business days or tell us when you will provide us with a response. Please furnish a letter that keys your responses to our comment and provide any requested supplemental information. Detailed letters greatly facilitate our review. Please understand that we may have additional comments after reviewing your response to our comments.

You may contact Amanda Roberts at (202) 551-3417 or me at (202) 551-3492 if you have any questions regarding comments on the financial statements and related matters.

Sincerely,
John P. Nolan
Accounting Branch Chief

Show Raw Text
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<SEQUENCE>1
<FILENAME>filename1.txt
<TEXT>

December 22, 2005

Mail Stop 4561

By U.S. Mail and facsimile to (410)237-5427

Mr. Edward J. Kelly, III
President and Chief Executive Officer
Mercantile Bankshares Corporation
Two Hopkins Plaza
P.O. Box 1477
Baltimore, MD 21203

Re:	Mercantile Bankshares Corporation
	Form 10-K for the Fiscal Year Ended December 31, 2004
      Filed March 15, 2005
	File No. 0-5127

Dear Mr. Kelly:

      We have reviewed your response letter dated December 9, 2005
and have the following additional comment.

Form 10-K, filed on March 15, 2005

Management`s Discussion and Analysis of Financial Condition and
Results of Operations

Non-GAAP Reconciliation, page 54
1. We note your response to comments 2 and 3 in our letter dated
November 17, 2005 regarding the useful information for investors
provided by the inclusion of non-GAAP financial measures.  Please
provide us with the proposed additional disclosures you will use
in
your 12/31/2005 financial statements to disclose the reasons
management believes that presentation of these non-GAAP financial
measures provides useful information to investors.  Please refer
to
Item 10(e)(i)(C) of Regulation S-K.

* * * * *

      Please respond to this comment within 10 business days or
tell
us when you will provide us with a response.  Please furnish a
letter
that keys your responses to our comment and provide any requested
supplemental information.  Detailed letters greatly facilitate our
review.  Please understand that we may have additional comments
after
reviewing your response to our comments.

       You may contact Amanda Roberts at (202) 551-3417 or me at
(202) 551-3492 if you have any questions regarding comments on the
financial statements and related matters.

Sincerely,

John P. Nolan
Accounting Branch Chief

Mr. Edward J. Kelly, III
Mercantile Bancshares Corporation
Page 1 of 2

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