SEC Comment Letter for CASS INFORMATION SYSTEMS INC (CASS) (CIK 0000708781) (CASS) — Aug 26, 2005
CASS INFORMATION SYSTEMS INC (CASS) (CIK 0000708781)
Date: Aug. 26, 2005 · CIK: 0000708781 · Accession: 0000000000-05-044529
AI Filing Summary & Sentiment
File numbers found in text: 333-44497
Referenced dates: August 2, 2005
Letter
Mail Stop 4561 VIA U.S. MAIL AND FAX 1-314-506-5560 Mr. Eric H. Brunngraber Chief Financial Officer Cass Information Systems 13001 Hollenberg Drive Bridgeton, Missouri 63044
RE: Cass Information Systems Form 10-KSB for the year ended December 31, 2004 Form 10-QSB for the quarter ended March 31, 2005 File no. 333-44497
Dear Mr. Brunngraber:
We have reviewed your response letter dated August 2, 2005 and have the following additional comments. These comments should be addressed in all future filings with the Commission, if indicated. Supplementally provide to us the information requested if indicated and please be as detailed as necessary in your explanation.
Form 10K for the fiscal year ended December 31, 2004
Consolidated Statements of Income, page 25
1. We have considered your response to comment 1 and question your classification of other income items (i.e. gain on sales of investment securities) within revenues. These amounts should be presented below net interest income after the provision for loan losses pursuant to Rule 9-04 of Regulation S-X. Please advise or revise future filings accordingly to reclassify these amounts.
Note 7 - Equity Investments in Non-Marketable Securities, page 36
2. We have reviewed your response to our prior comment 3. Given the investee has "performed poorly during the past few years", it is unclear why you believe the extension of a credit line does not create some level of dependence on your Company as the investor. This combined with your board representation appears to indicate you may have significant influence over this investee. Further, majority ownership interest by another investor does not necessary preclude the ability to exercise significant influence. Please further advise us your consideration of the facts and circumstances that lead you to believe that you have no significant influence over this investee.
* * * *
Please respond to these comments within ten business days. Please file your response on EDGAR.
You may contact Kelly McCusker, Staff Accountant, at (202) 551- or the undersigned at (202) 551-3413 if you have questions.
Sincerely,
Cicely D. Luckey
Branch Chief
Show Raw Text
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<TEXT>
August 26, 2005
Mail Stop 4561
VIA U.S. MAIL AND FAX 1-314-506-5560
Mr. Eric H. Brunngraber
Chief Financial Officer
Cass Information Systems
13001 Hollenberg Drive
Bridgeton, Missouri 63044
RE: Cass Information Systems
Form 10-KSB for the year ended December 31, 2004
Form 10-QSB for the quarter ended March 31, 2005
File no. 333-44497
Dear Mr. Brunngraber:
We have reviewed your response letter dated August 2, 2005 and
have
the following additional comments. These comments should be
addressed in all future filings with the Commission, if indicated.
Supplementally provide to us the information requested if
indicated
and please be as detailed as necessary in your explanation.
Form 10K for the fiscal year ended December 31, 2004
Consolidated Statements of Income, page 25
1. We have considered your response to comment 1 and question your
classification of other income items (i.e. gain on sales of
investment securities) within revenues. These amounts should be
presented below net interest income after the provision for loan
losses pursuant to Rule 9-04 of Regulation S-X. Please advise or
revise future filings accordingly to reclassify these amounts.
Note 7 - Equity Investments in Non-Marketable Securities, page 36
2. We have reviewed your response to our prior comment 3. Given
the
investee has "performed poorly during the past few years", it is
unclear why you believe the extension of a credit line does not
create some level of dependence on your Company as the investor.
This combined with your board representation appears to indicate
you
may have significant influence over this investee. Further,
majority
ownership interest by another investor does not necessary preclude
the ability to exercise significant influence. Please further
advise
us your consideration of the facts and circumstances that lead you
to
believe that you have no significant influence over this investee.
* * * *
Please respond to these comments within ten business days. Please
file your response on EDGAR.
You may contact Kelly McCusker, Staff Accountant, at (202) 551-
3433
or the undersigned at (202) 551-3413 if you have questions.
Sincerely,
Cicely D. Luckey
Branch Chief
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Mr. Brunngraber
Cass Information Systems, Inc.
August 26, 2005
Page 1
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