SEC Comment Letter 0000000000-23-014020 to FIRST FINANCIAL BANCORP /OH/ (FFBC) (CIK 0000708955) (FFBC)
FIRST FINANCIAL BANCORP /OH/ (FFBC) (CIK 0000708955)
Date: Dec. 22, 2023 · CIK: 0000708955 · Accession: 0000000000-23-014020
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File numbers found in text: 001-34762
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United States securities and exchange commission logo
December 22, 2023
James M. Anderson
Executive Vice President and Chief Financial Officer
First Financial Bancorp.
255 East Fifth Street Suite 800
Cincinnati, OH 45202
Re:First Financial Bancorp.
Form 10-K for Fiscal Year Ended December 31, 2022
File No. 001-34762
Dear James M. Anderson:
We have limited our review of your filing to the financial statements and related
disclosures and have the following comments.
Please respond to this letter within ten business days by providing the requested
information or advise us as soon as possible when you will respond. If you do not believe a
comment applies to your facts and circumstances, please tell us why in your response.
After reviewing your response to this letter, we may have additional comments.
Form 10-K for the period ended December 31, 2022
Exhibit 13: Registrant's annual report to shareholders for the year ended December 31, 2022
Loans and Leases, page 16
1.We note the tabular disclosure on page 17 detailing the composition of your gross loan
portfolio, which includes commercial real estate (“CRE”). Given the significance of CRE
in your total loan portfolio, please revise your disclosures, in future filings, to further
disaggregate the composition of your CRE loan portfolio by borrower type (e.g., by office,
hotel, multifamily, etc.), geographic concentrations and other characteristics (e.g., current
weighted average and/or range of loan-to-value ratios, occupancy rates, etc.), if any. In
addition, revise to describe the specific details of any risk management policies,
procedures or other actions undertaken by management in response to the current
environment.
Market Risk, page 30
2.We note your disclosures regarding risk management processes and, on page 32, liquidity
risk management-related items that management is closely monitoring. In future filings,
FirstName LastNameJames M. Anderson
Comapany NameFirst Financial Bancorp.
December 22, 2023 Page 2
FirstName LastName
James M. Anderson
First Financial Bancorp.
December 22, 2023
Page 2
please enhance your disclosures to:
•note the existence of oversight committees such as an Asset Liability Committee or
similar, and the membership and responsibilities of such committees, as applicable;
•discuss any material liquidity policy guidelines or limits, including depositor or other
concentration limits, and provide examples of specific metrics used to manage
liquidity within those guidelines; and
•to the extent applicable, disclose whether you have been in compliance with such
policy guidelines or related limits and, if not, planned actions to remediate non-
compliance.
3.In future filings, please consider expanding the discussion of your contingency funding
plan to provide additional detail regarding types of revisions and / or to describe actions
that would be taken to address liquidity risk during a stress event, such as balance sheet
repositioning, capital raises, promotional efforts for deposits, increased usage of brokered
deposits, etc., as applicable.
Critical Accounting Estimates, page 34
4.We note your disclosure for critical accounting estimates. Please revise your disclosures,
in future filings, to explain why each critical accounting estimate is subject to uncertainty
and, to the extent the information is material and reasonably available, (i) provide
qualitative and quantitative information necessary to understand the estimation uncertainty
and the impact the critical accounting estimate has had or is reasonably likely to have on
financial condition or results of operations, and (ii) explain how much each estimate
and/or assumption has changed over a relevant period, and the sensitivity of the reported
amounts to the material methods, assumptions and estimates underlying its calculation.
Ensure that the disclosure of your critical accounting estimates is not a repetition of your
significant accounting policies. Refer to Item 303(b)(3) of Regulation S-K.
In closing, we remind you that the company and its management are responsible for the
accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or
absence of action by the staff.
Please contact Lory Empie at 202-551-3714 or Cara Lubit at 202-551-5909 with any
questions.
Sincerely,
Division of Corporation Finance
Office of Finance