SEC Comment Letter 0000000000-24-010162 to PEOPLES BANCORP INC (PEBO) (CIK 0000318300) (PEBO)
PEOPLES BANCORP INC (PEBO) (CIK 0000318300)
Date: Sept. 9, 2024 · CIK: 0000318300 · Accession: 0000000000-24-010162
AI Filing Summary & Sentiment
File numbers found in text: 000-16772
Letter
September 9, 2024 Kathryn Bailey Chief Financial Officer Peoples Bancorp Inc. 138 Putnam Street, PO Box 738 Marietta, OH 45750 Re:Peoples Bancorp Inc. Form 10-K for Fiscal Year Ended December 31, 2023 File No. 000-16772 Dear Kathryn Bailey: We have limited our review of your filing to the financial statements and related disclosures and have the following comment. 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 Item 7 Management's Discussion and Analysis of Financial Condition and Results of Operations Results of Operations, page 48 1.We note your disclosure on page 58 of "pre-provision net revenue per common share – diluted" and “pre-provision net revenue to total average assets.” We also note that these measures are presented in certain of your current reports, such as your news release included in Form 8-K on July 23, 2024. Please tell us how you determined that these measures do not represent individually tailored accounting measures. Refer to Question 100.04 of the Division of Corporation Finance’s Compliance & Disclosure Interpretations on Non-GAAP Financial Measures and Rule 100(b) of Regulation G. 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.
September 9, 2024 Page 2 Please contact Katharine Garrett at 202-551-2332 or John Nolan at 202-551-3492 with any questions. Sincerely, Division of Corporation Finance Office of Finance
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September 9, 2024
Kathryn Bailey
Chief Financial Officer
Peoples Bancorp Inc.
138 Putnam Street, PO Box 738
Marietta, OH 45750
Re:Peoples Bancorp Inc.
Form 10-K for Fiscal Year Ended December 31, 2023
File No. 000-16772
Dear Kathryn Bailey:
We have limited our review of your filing to the financial statements and related
disclosures and have the following comment.
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
Item 7 Management's Discussion and Analysis of Financial Condition and Results of Operations
Results of Operations, page 48
1.We note your disclosure on page 58 of "pre-provision net revenue per common share –
diluted" and “pre-provision net revenue to total average assets.” We also note that these
measures are presented in certain of your current reports, such as your news release
included in Form 8-K on July 23, 2024. Please tell us how you determined that these
measures do not represent individually tailored accounting measures. Refer to Question
100.04 of the Division of Corporation Finance’s Compliance & Disclosure Interpretations
on Non-GAAP Financial Measures and Rule 100(b) of Regulation G.
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.
September 9, 2024
Page 2
Please contact Katharine Garrett at 202-551-2332 or John Nolan at 202-551-3492 with
any questions.
Sincerely,
Division of Corporation Finance
Office of Finance