SEC Comment Letter for FULTON FINANCIAL CORP (FULT, FULTP) (CIK 0000700564) (FULT) — Nov 17, 2010
FULTON FINANCIAL CORP (FULT, FULTP) (CIK 0000700564)
Date: Nov. 17, 2010 · CIK: 0000700564 · Accession: 0000000000-10-068755
AI Filing Summary & Sentiment
Referenced dates: June 28, 2010
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UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549
DIVISION OF
CORPORATION FINANCE
November 17, 2010
By U.S. Mail and Facsimile to: ( 717) 295- 5312
Charles J. Nugent
Senior Executive Vice President and Chief Financial Officer
Fulton Financial Corporation One Penn Square
P.O. Box 4887 Lancaster, Pennsylvania 17604
Re: Fulton Financial Corporation
Form 10- K for the Fis cal Year Ended December 31, 2009
Form 10- Q for the Quarterly Period Ended March 31, 2010
File No. 000 -10587
Dear Mr. Nugent :
We have reviewed your July 26, 2010 response to our comments and have the
following additional comment .
Please respond to this letter within ten business da ys by prov iding the requested
information or by advising us when you will provide the requested response. If you do
not believe our comments apply to your facts and circumstances, please tell us why in your response.
After reviewing the information you provide in response to these comments, we
may have additional comments.
Form 10- K for the Fiscal Year E nded December 31, 2009
Exhibits and Financial Statement Schedules, page 102
1. We note your response to comment 4 in our letter dated June 28, 2010 and we are
unable to agree with your analysis. Item 601(b)(10)(iii)(A) of Regulation S -K
provides that if a plan is not set forth in any formal document, a written description of the plan shall be filed. Please file a written description of the Variable Compensation Plan as an exhibit to your next periodic report.
Charles J. Nugent
Fulton Financial Corporation
November 17, 2010
Page 2
Closing Comments
You may contact Benjamin Phippen at (202) 551- 3697 or Amit Pande ,
Accounting Branch Chief, at (202) 551- 3423 if you have questions regarding comments
on the financial statements and related matters. Please contact Justi n Dobbie at (202)
551-3469 or me at (202) 551- 3434 with any other questions.
Sincerely,
Michael R. Clampitt
Senior Attorney Advisor