SEC Comment Letter for CVB FINANCIAL CORP (CVBF) (CIK 0000354647) (CVBF) — Apr 19, 2012
CVB FINANCIAL CORP (CVBF) (CIK 0000354647)
Date: April 19, 2012 · CIK: 0000354647 · Accession: 0000000000-12-020068
AI Filing Summary & Sentiment
Referenced dates: November 29, 2011
Letter
April 19, 2012 Via E-mail Christopher D. Myers President and Chief Executive Officer CVB Financial Corp. 701 N. Haven Avenue, Suite 350 Ontario, California 91764
Re: CVB Financial Corp. Form 10-K for the Fiscal Year Ended December 31, 2011 Filed February 29, 2012 Form 10-K for the Fiscal Year Ended December 31, 2010 Filed March 1, 2011 File No. 0-10140
Dear Mr. Myers: We have reviewed your response letter date d February 21, 2012 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 this letter within ten business days by amending your filing, by providing the requested information, or by advi sing us when you will provide the requested response. If you do not believe our comments apply to your fact s and circumstances or do not believe an amendment is appropriate, pl ease tell us why in your response.
After reviewing any amendment to your filing and the information you provide in response to these comments, we may have additional comments. Form 10-K for the fiscal year ended December 31, 2011
Management’s Discussion and Analysis of Fi nancial Condition and Results of Operations
Non-Performing Assets (Non-Covered), page 60 1. We note your response to comments 1 and 5 of our letter dated November 29, 2011 which indicates that you are relying on the global cash flows of the primary borrower and any guarantors and all their respective related en tities in determining whether a borrower is experiencing financial difficulties. Please te ll us how you considered the guidance in ASC 310-40-15-20 and in particular ASC 310-40-15-20 (e), which requires you to forecast the debtor’s ability to service its debt with ent ity-specific cash flows, when determining whether
Christopher D. Myers CVB Financial Corp. April 19, 2012 Page 2
a borrower is experiencing financial difficulty and whether a given modification should be accounted for as a trouble d debt restructuring. You may contact Benjamin Phi ppen, Staff Accountant, at (2 02) 551-3697 or me at (202) 551-3423 if you have questions. Sincerely, /s/ Amit Pande Amit Pande Accounting Branch Chief
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April 19, 2012 Via E-mail Christopher D. Myers President and Chief Executive Officer CVB Financial Corp. 701 N. Haven Avenue, Suite 350 Ontario, California 91764 Re: CVB Financial Corp. Form 10-K for the Fiscal Year Ended December 31, 2011 Filed February 29, 2012 Form 10-K for the Fiscal Year Ended December 31, 2010 Filed March 1, 2011 File No. 0-10140 Dear Mr. Myers: We have reviewed your response letter date d February 21, 2012 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 this letter within ten business days by amending your filing, by providing the requested information, or by advi sing us when you will provide the requested response. If you do not believe our comments apply to your fact s and circumstances or do not believe an amendment is appropriate, pl ease tell us why in your response. After reviewing any amendment to your filing and the information you provide in response to these comments, we may have additional comments. Form 10-K for the fiscal year ended December 31, 2011 Management’s Discussion and Analysis of Fi nancial Condition and Results of Operations Non-Performing Assets (Non-Covered), page 60 1. We note your response to comments 1 and 5 of our letter dated November 29, 2011 which indicates that you are relying on the global cash flows of the primary borrower and any guarantors and all their respective related en tities in determining whether a borrower is experiencing financial difficulties. Please te ll us how you considered the guidance in ASC 310-40-15-20 and in particular ASC 310-40-15-20 (e), which requires you to forecast the debtor’s ability to service its debt with ent ity-specific cash flows, when determining whether Christopher D. Myers CVB Financial Corp. April 19, 2012 Page 2 a borrower is experiencing financial difficulty and whether a given modification should be accounted for as a trouble d debt restructuring. You may contact Benjamin Phi ppen, Staff Accountant, at (2 02) 551-3697 or me at (202) 551-3423 if you have questions. Sincerely, /s/ Amit Pande Amit Pande Accounting Branch Chief