Correspondence 0001628280-24-051056 from OLD NATIONAL BANCORP /IN/ (ONB, ONBPO, ONBPP) (CIK 0000707179) (ONB)
OLD NATIONAL BANCORP /IN/ (ONB, ONBPO, ONBPP) (CIK 0000707179)
Date: Dec. 12, 2024 · CIK: 0000707179 · Accession: 0001628280-24-051056
AI Filing Summary & Sentiment
File numbers found in text: 001-15817
Referenced dates: November 14, 2024
Letter
Document
December 12, 2024
Via EDGAR
Division of Corporation Finance
Office of Finance
United States Securities and Exchange Commission
100 F. Street, N.E.
Washington, D.C.20549
Attn: Ms. Shannon Davis
Mr. Michael Volley
Mr. Robert Arzonetti
Mr. Christian Windsor
Re: Old National Bancorp
Form 10-K for the Fiscal Year Ended December 31, 2023
Letter dated November 14, 2024
File No. 001-15817
Ladies and Gentlemen:
Set forth below is the response from Old National Bancorp (the “Company,” “we” or “our”) to the comment letter from the staff (the “Staff”) of the Division of Corporation Finance of the U.S. Securities and Exchange Commission (the “Commission”), dated November 14, 2024 (the “Comment Letter”), concerning the Company’s Annual Report on Form 10-K for the fiscal year ended December 31, 2023.
For convenience of the Staff’s review, we have set forth below the comment of the Staff in the Comment Letter, with the Company’s response thereto immediately following. Capitalized terms used but not otherwise defined in this letter have the meanings ascribed to such terms in the Company’s Annual Report on Form 10-K for the fiscal year ended December 31, 2023.
Form 10-K for the Fiscal Year Ended December 31, 2023
Financial Condition
Loan Portfolio
Commercial and Commercial Real Estate Loans, page 50
1. We note your response to prior comment 2. Please confirm that in future filings you
will provide additional disclosure to explain the circumstances which must be met in
order to approve a commercial loan that exceeds the 80% LTV threshold. We note
that you provide a discussion of the process for approving exceptions in your
discussion of your process for approving consumer loans.
Response:
We respectfully acknowledge the Staff’s comment and will provide additional disclosures to explain the circumstances which must be met in order to approve a commercial loan that exceeds the 80% LTV threshold in our future filings with the Commission.
If you have further questions or require additional clarifying information, please contact Angela Putnam, Chief Accounting Officer, at (773) 765-7733, Michael Woods, Corporate Controller, at (812) 461-9067, or Mike Ebner, Senior Assistant General Counsel, at (773) 628-5474.
Sincerely,
/s/ John V. Moran IV
Show Raw Text
CORRESP 1 filename1.htm Document December 12, 2024 Via EDGAR Division of Corporation Finance Office of Finance United States Securities and Exchange Commission 100 F. Street, N.E. Washington, D.C.20549 Attn: Ms. Shannon Davis Mr. Michael Volley Mr. Robert Arzonetti Mr. Christian Windsor Re: Old National Bancorp Form 10-K for the Fiscal Year Ended December 31, 2023 Letter dated November 14, 2024 File No. 001-15817 Ladies and Gentlemen: Set forth below is the response from Old National Bancorp (the “Company,” “we” or “our”) to the comment letter from the staff (the “Staff”) of the Division of Corporation Finance of the U.S. Securities and Exchange Commission (the “Commission”), dated November 14, 2024 (the “Comment Letter”), concerning the Company’s Annual Report on Form 10-K for the fiscal year ended December 31, 2023. For convenience of the Staff’s review, we have set forth below the comment of the Staff in the Comment Letter, with the Company’s response thereto immediately following. Capitalized terms used but not otherwise defined in this letter have the meanings ascribed to such terms in the Company’s Annual Report on Form 10-K for the fiscal year ended December 31, 2023. Form 10-K for the Fiscal Year Ended December 31, 2023 Financial Condition Loan Portfolio Commercial and Commercial Real Estate Loans, page 50 1. We note your response to prior comment 2. Please confirm that in future filings you will provide additional disclosure to explain the circumstances which must be met in order to approve a commercial loan that exceeds the 80% LTV threshold. We note that you provide a discussion of the process for approving exceptions in your discussion of your process for approving consumer loans. Response: We respectfully acknowledge the Staff’s comment and will provide additional disclosures to explain the circumstances which must be met in order to approve a commercial loan that exceeds the 80% LTV threshold in our future filings with the Commission. If you have further questions or require additional clarifying information, please contact Angela Putnam, Chief Accounting Officer, at (773) 765-7733, Michael Woods, Corporate Controller, at (812) 461-9067, or Mike Ebner, Senior Assistant General Counsel, at (773) 628-5474. Sincerely, /s/ John V. Moran IV John V. Moran IV Senior Executive Vice President and Chief Financial Officer Cc: James C. Ryan III, Chairman and Chief Executive Officer, Old National Bancorp Nicholas J. Chulos, Executive Vice President, Chief Legal Officer, and Corporate Secretary, Old National Bancorp