SEC Comment Letter for HORIZON BANCORP (HBNC) — Dec 1, 2010
HORIZON BANCORP INC /IN/ (HBNC) (CIK 0000706129)
Date: Dec. 1, 2010 · CIK: 0000706129 · Accession: 0000000000-10-071675
AI Filing Summary & Sentiment
Reasoning
Letter
Re: Horizon Bancorp Form 10-Q for the Quarterly Period Ended June 30, 2010 Filed August 12, 2010 File No. 0-10792 Dear Mr. Secor: We have reviewed supplemental response a nd have the following comment. In our comment, we ask you to provide us with in formation so we may better understand your disclosure. Please respond to this letter within te n business days by providing the requested information, including a draft of your proposed disclosures to be made in future filings, or by advising us when you will provide the requested response. If you do not believe our comment applies to your facts and circumstances or do not believe future revisions are appropriate, please tell us why in your response. After reviewing the information you provide in response to these comment, including the draft of your proposed disclosures, we may have additional comments. Form 10-Q for the Quarterly Period Ended June 30, 2010
November 8, 2010
Mark E. Secor Chief Financial Officer Horizon Bancorp 515 Franklin Square Michigan City, Indiana 46360
General
1. We note your response to Comment 3 of our letter dated Sept ember 21, 2010. Please tell us how you determined that Items I, III, IV and V of Industry Guide III were not relevant and/or material to your interi m operations in light of the changes in asset and liability balances and activity in the al lowance for loan losses during the period. Otherwise, please revise future filings to include these re quired disclosures.
We urge all persons who are responsible for th e accuracy and adequacy of the disclosure in the filing to be certain that the filing include s the information the Securities Exchange Act of 1934 and all applicable Exchange Act rules requir e. Since the company and its management are in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy and adequacy of the disclosures they have made.
Mark E. Secor Horizon Bancorp November 8, 2010 Page 2
In responding to our comment, please provide a written statement from the company acknowledging 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.
You may contact William Schr oeder, Staff Accountant, at (202) 551-3294 or Kevin W. Vaughn, Accounting Branch Chief, at (202) 551- 3494 if you have questions regarding comments on the financial statements and related matters.
Sincerely,
Kevin W. Vaughn
Accounting Branch Chief
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November 8, 2010
Mark E. Secor Chief Financial Officer Horizon Bancorp 515 Franklin Square
Michigan City, Indiana 46360
Re: Horizon Bancorp Form 10-Q for the Quarterly Period Ended June 30, 2010
Filed August 12, 2010 File No. 0-10792
Dear Mr. Secor:
We have reviewed supplemental response a nd have the following comment. In our
comment, we ask you to provide us with in formation so we may better understand your
disclosure.
Please respond to this letter within te n business days by providing the requested
information, including a draft of your proposed disclosures to be made in future filings, or by
advising us when you will provide the requested response. If you do not believe our comment
applies to your facts and circumstances or do not believe future revisions are appropriate, please
tell us why in your response.
After reviewing the information you provide in response to these comment, including the
draft of your proposed disclosures, we may have additional comments.
Form 10-Q for the Quarterly Period Ended June 30, 2010
General
1. We note your response to Comment 3 of our letter dated Sept ember 21, 2010. Please tell
us how you determined that Items I, III, IV and V of Industry Guide III were not relevant and/or material to your interi m operations in light of the changes in asset and liability
balances and activity in the al lowance for loan losses during the period. Otherwise, please
revise future filings to include these re quired disclosures.
We urge all persons who are responsible for th e accuracy and adequacy of the disclosure
in the filing to be certain that the filing include s the information the Securities Exchange Act of
1934 and all applicable Exchange Act rules requir e. Since the company and its management are
in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy
and adequacy of the disclosures they have made.
Mark E. Secor
Horizon Bancorp November 8, 2010 Page 2
In responding to our comment, please provide a written statement from the company
acknowledging 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.
You may contact William Schr oeder, Staff Accountant, at (202) 551-3294 or Kevin W.
Vaughn, Accounting Branch Chief, at (202) 551- 3494 if you have questions regarding comments
on the financial statements and related matters.
Sincerely,
Kevin W. Vaughn
Accounting Branch Chief