SecProbe.io

September 12, 2024
Judith I. Wawroski
Chief Accounting Officer and Treasurer
International Bancshares Corporation
1200 San Bernardo Avenue
Laredo, TX 78042
Re:International Bancshares Corporation
Form 10-K for Fiscal Year Ended December 31, 2023
Form 10-Q for Fiscal Quarter Ended June 30, 2024
File No. 000-09439
Dear Judith I. Wawroski:
            We have limited our review of your filing to the financial statements and related
disclosures and have the following comments.
            Please respond to this letter within ten business days by providing the requested
information or advise us as soon as possible when you will respond. If you do not believe a
comment applies to your facts and circumstances, please tell us why in your response.
            After reviewing your response to this letter, we may have additional comments.
Form 10-K for Fiscal Year Ended December 31, 2023
Exhibit 13
Management's Discussion and Analysis of Financial Condition and Results of Operations, page 2
1.We note your disclosure on page 12 that your commercial real estate (“CRE”) loans are
disaggregated into three classes: other construction & land development, farmland
& commercial, and multifamily loans. We also note that your total CRE loans among
these three classes were approximately $5.3 billion at December 31, 2023, which
comprised about 65% of your total gross loans. Please revise your future periodic filings
to further disaggregate the composition of your CRE loan portfolio to address material
geographic and other concentrations to the extent material to an investor’s understanding
of your CRE loan portfolio. In this regard, provide quantitative and qualitative disclosure
regarding owner-occupied and non-owner-occupied CRE loans, current weighted average
and/or range of loan-to-value ratios and occupancy rates, if available, and disclose the
extent of your exposure by industry or borrower type, such as office, retail, hotel and
multifamily, etc.

September 12, 2024
Page 2
2.We note your statement on page 20 that your CRE loans “carry risk of repayment when
market values deteriorate, the business experiences turnover in key management, the
business has an inability to attract or keep occupancy levels stable, or the market
experiences an exit of a specific business type that is significant to the local economy,
such as a manufacturing plant.” Additionally, we note that the total of non-accrual loans
among your three CRE loan classes increased by approximately $84.5 million at June 30,
2024, when compared to December 31, 2023, as disclosed in the table on page 20 of your
Form 10-Q for the fiscal quarter ended June 30, 2024. Please revise your future periodic
filings to clarify the specific risk management policies, procedures or other actions
undertaken by management in response to the current CRE environment.
Liquidity and Capital Resources, page 15
3.We note your disclosure of various funding sources used by, and available to, the
Company, such as deposits and lines of credit. Please revise your future periodic filings to
disclose quantitative amounts of material sources of liquidity, to the extent it is necessary
to understand your financial condition, any current and anticipated material changes in
trends related to your liquidity requirements and your plans related to such changes.
Additionally, please revise your future periodic filings to include a discussion of material
cash requirements from known contractual and other obligations, separately in the short-
term and long-term. Please refer to Item 303(b)(1) of Regulation S-K.
Notes to Consolidated Financial Statements
(4) Allowance for Credit Losses, page 46
4.We note your disclosure on page 51 of loans accounted for on a non-accrual basis. Please
revise your future periodic filings to also disclose the amortized cost basis of your loans
on non-accrual status, disaggregated by class of loan, for which there is no related
allowance for credit losses as of the reporting date. Please refer to ASC 326-20-50-16.
Form 10-Q for Fiscal Quarter Ended June 30, 2024
Notes to Consolidated Financial Statements
Note 2 – Fair Value Measurements, page 10
5.We note your tabular disclosure on page 12 of assets measured at fair value on a non-
recurring basis. We also note your disclosure that you had $101.7 million and $46.5
million of doubtful commercial collateral dependent loans as of June 30, 2024 and
December 31, 2023, respectively. Please tell us how the amount of “Watch List –
Doubtful Loans” in the tabular presentation on page 12 reconciles to the amount of
doubtful commercial collateral dependent loans noted above, at both of the June 30, 2024
and December 31, 2023 reporting dates. In your response, please also tell us how the
above noted balances relate to the amount of such loans which had an appraisal or internal
evaluation performed within the immediately preceding twelve months. Please revise
future periodic filings as appropriate to clearly describe how these amounts are related.
Note 4 – Allowance for Credit Losses, page 15
We note your disclosure on page 19 that you recognized a charge-down of approximately
$25.6 million in the six months ended June 30, 2024, related to a commercial loan secured 6.

September 12, 2024
Page 3
by equipment and pipeline infrastructure used in the oil and gas industry. We also note
your disclosure that the customer declared bankruptcy in the third quarter of 2023, and
that the assets collateralizing the loan were awarded to a principal owner of the business
upon foreclosure in March 2024. Please address the following:
•Tell us how the allowance for credit losses related to this loan was determined and
reported in prior quarterly and annual periods from the point it was classified as
Watch List – Doubtful and concurrently placed on non-accrual status in the fourth
quarter of 2022 through the customer’s bankruptcy in the third quarter of 2023 and
the charge-down in the first quarter of 2024.
•Additionally, please tell us how you concluded that no disclosure was required related
to the customer’s bankruptcy proceedings in your Form 10-Q for the fiscal quarter
ended September 30, 2023, or your Form 10-K for the fiscal year ended December
31, 2023, considering the disclosure objectives in ASC 326-20-50.
7.We note from the table presenting balances of loans individually or collectively evaluated
for impairment at the bottom of page 19 and additional disclosures on page 20 that there
was an increase in commercial real estate multifamily loans individually evaluated for
impairment at June 30, 2024 attributed to two relationships secured by apartments that
were downgraded to Watch List – Doubtful in the first six months of 2024. We further
note that there was no allowance related to these loans at June 30, 2024. Given your
policy disclosure on page 16 that substantially all of your loans evaluated as Watch List –
Doubtful are measured using the fair value of collateral method, please tell us in detail
how you determined the fair value of the collateral related to these loans and concluded
that no allowance was required, including any consideration given to the guidance in ASC
326-20-35-4 and 35-5.
            In closing, we remind you 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.
            Please contact Katharine Garrett at 202-551-2332 or Amit Pande at 202-551-3423 with
any questions.
Sincerely,
Division of Corporation Finance
Office of Finance