SEC Comment Letter 0000000000-24-012153 to Ameris Bancorp (ABCB) (CIK 0000351569) (ABCB)
Ameris Bancorp (ABCB) (CIK 0000351569)
Date: Oct. 31, 2024 · CIK: 0000351569 · Accession: 0000000000-24-012153
AI Filing Summary & Sentiment
File numbers found in text: 001-13901
Letter
October 31, 2024 Nicole S. Stokes Corporate EVP and Chief Financial Officer Ameris Bancorp 3490 Piedmont Road N.E., Suite 1550 Atlanta, Georgia 30305 Re:Ameris Bancorp Form 10-K for Fiscal Year Ended December 31, 2023 File No. 001-13901 Dear Nicole S. Stokes: 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 Item 7. Management's Discussion and Analysis of Financial Condition and Results of Operations Loans, page 40 We note from your tabular disclosure on page 41, that the combination of two loan categories presented as construction and development, as well as commercial and farmland real estate loans represent a significant portion of your total loan portfolio as of December 31, 2023. We further note your disclosure on page F-17 that commercial real estate (“CRE”) loans may be larger in size and may involve a greater degree of risk than one-to-four family residential mortgage loans and that payments on such loans are often dependent on successful operation or management of the properties. Please revise future filings to further disaggregate the composition of your CRE loan portfolio to address 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 current weighted average and/or range of loan-to-value ratios and occupancy rates, if available, as well as other factors to the extent material to an investor’s understanding of the risks inherent in your CRE 1.
October 31, 2024 Page 2 loan portfolio.
We note the reference on page 7 to national and local economic pressures, the rising interest rate environment and other factors impacting banks. We also note the reference on page 48 to management and the ALCO Committee conducting evaluations “when economic or market concerns warrant such evaluation.” Please revise future filings to clarify the specific risk management policies, procedures or other actions undertaken by management in response to risks relating to the commercial real estate market in the current environment. 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 Victor Cecco at 202-551-2064 or John Nolan at 202-551-3492 with any questions. Sincerely, Division of Corporation Finance Office of Finance
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October 31, 2024
Nicole S. Stokes
Corporate EVP and Chief Financial Officer
Ameris Bancorp
3490 Piedmont Road N.E., Suite 1550
Atlanta, Georgia 30305
Re:Ameris Bancorp
Form 10-K for Fiscal Year Ended December 31, 2023
File No. 001-13901
Dear Nicole S. Stokes:
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
Item 7. Management's Discussion and Analysis of Financial Condition and Results of
Operations
Loans, page 40
We note from your tabular disclosure on page 41, that the combination of two loan
categories presented as construction and development, as well as commercial and
farmland real estate loans represent a significant portion of your total loan portfolio as
of December 31, 2023. We further note your disclosure on page F-17 that commercial
real estate (“CRE”) loans may be larger in size and may involve a greater degree of
risk than one-to-four family residential mortgage loans and that payments on such
loans are often dependent on successful operation or management of the properties.
Please revise future filings to further disaggregate the composition of your CRE loan
portfolio to address 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 current weighted average and/or
range of loan-to-value ratios and occupancy rates, if available, as well as other factors
to the extent material to an investor’s understanding of the risks inherent in your CRE 1.
October 31, 2024
Page 2
loan portfolio.
We note the reference on page 7 to national and local economic pressures, the rising
interest rate environment and other factors impacting banks. We also note the
reference on page 48 to management and the ALCO Committee conducting
evaluations “when economic or market concerns warrant such evaluation.” Please
revise future filings to clarify the specific risk management policies, procedures or
other actions undertaken by management in response to risks relating to the
commercial real estate market in the current environment.
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 Victor Cecco at 202-551-2064 or John Nolan at 202-551-3492 with
any questions.
Sincerely,
Division of Corporation Finance
Office of Finance