SEC Company Response from FULTON FINANCIAL CORP (FULT, FULTP) (CIK 0000700564) (FULT) — Nov 24, 2010
FULTON FINANCIAL CORP (FULT, FULTP) (CIK 0000700564)
Date: Nov. 24, 2010 · CIK: 0000700564 · Accession: 0001193125-10-268804
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 000-10587
Referenced dates: June 28, 2010, November 17, 2010
Letter
Securities and Exchange Commission Fulton Financial Corporation Form 10-K for the Fiscal Year Ended December 31, 2009 Form 10-Q for the Quarterly Period Ended March 31, 2010 File No. 000-10587
Re:
Dear Mr. Clampitt:
Fulton Financial Corporation (the “Company”) submits this letter in response to comments of the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”) dated November 17, 2010 relating to the above-referenced filings. In this letter, we have recited the comments from the staff in bold type and have followed each comment with the Company’s response.
Form 10-K for the Fiscal Year Ended 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.
Response – A written description of the Company’s Variable Compensation Plan will be included as an exhibit to our next periodic report.
Michael R. Clampitt
Securities and Exchange Commission
November 24, 2010
Page
Fulton Financial Corporation hereby acknowledges that:
•
The Company is responsible for the adequacy and accuracy of the disclosure in the filing;
•
Staff comments or changes to disclosure in response to Staff comments do not foreclose the Commission from taking any action with respect to the filing; and
•
The Company may not assert Staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.
If you have further questions, please do not hesitate to call myself at 717-291-2473 or Ms. Betsy Chivinski, Corporate Controller, at 717-291-2689.
Sincerely,
/s/ Charles J. Nugent
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CORRESP 1 filename1.htm Correspondence November 24, 2010 Michael R. Clampitt Senior Attorney Advisor Securities and Exchange Commission 450 Fifth Street, N.W. Washington, D.C. 20549 Re: Fulton Financial Corporation Form 10-K for the Fiscal Year Ended December 31, 2009 Form 10-Q for the Quarterly Period Ended March 31, 2010 File No. 000-10587 Dear Mr. Clampitt: Fulton Financial Corporation (the “Company”) submits this letter in response to comments of the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”) dated November 17, 2010 relating to the above-referenced filings. In this letter, we have recited the comments from the staff in bold type and have followed each comment with the Company’s response. Form 10-K for the Fiscal Year Ended 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. Response – A written description of the Company’s Variable Compensation Plan will be included as an exhibit to our next periodic report. Michael R. Clampitt Securities and Exchange Commission November 24, 2010 Page 2 Fulton Financial Corporation hereby acknowledges that: • The Company is responsible for the adequacy and accuracy of the disclosure in the filing; • Staff comments or changes to disclosure in response to Staff comments do not foreclose the Commission from taking any action with respect to the filing; and • The Company may not assert Staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States. If you have further questions, please do not hesitate to call myself at 717-291-2473 or Ms. Betsy Chivinski, Corporate Controller, at 717-291-2689. Sincerely, /s/ Charles J. Nugent Charles J. Nugent Senior Executive Vice President and Chief Financial Officer