SEC Comment Letter 0000000000-23-013551 to CAMBRIDGE BANCORP (CIK 0000711772)
CAMBRIDGE BANCORP (CIK 0000711772)
Date: Dec. 12, 2023 · CIK: 0000711772 · Accession: 0000000000-23-013551
AI Filing Summary & Sentiment
File numbers found in text: 001-38184
Letter
United States securities and exchange commission logo December 12, 2023 Michael Carotenuto Chief Financial Officer Cambridge Bancorp 1336 Massachusetts Avenue Boston, MA 02138 Re:Cambridge Bancorp Form 10-K for the year ended December 31, 2022 Form 10-Q for the quarter ended September 30, 2023 File No. 001-38184 Dear Michael Carotenuto: We have reviewed your filings and have the following comment. 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. Quarterly Report on Form 10-Q for the quarterly period ended September 30, 2023 Market Risk and Asset Liability Management, page 50 1.We note the statement on page 50 that various reports are "compared to limits established by the Company’s ALCO policies and appropriate adjustments may be made if the results are outside the established limits." Please revise future filings to include a materially complete description of how you seek to manage risks due to changes in interest rates and other material impacts on your operational facts and circumstances, including any management or corporate governance controls or procedures for identifying and responding to rapid changes in interest rates due to or as a result of exogenous or unknown factors. For example, it is unclear if the 18.9% decrease in the economic value of equity referenced on page 51 was outside established limits. Please clarify the ALCO- approved limits and, with a view to disclosure, advise us of the extent to which the ALCO has approved risk profiles that do not conform to management and Board risk tolerances. Clarify the extent to which such limits and other policies and controls have been changed due to the economic and other developments referenced elsewhere.
FirstName LastNameMichael Carotenuto Comapany NameCambridge Bancorp December 12, 2023 Page 2 FirstName LastName Michael Carotenuto Cambridge Bancorp December 12, 2023 Page 2 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 Michael Volley at 202-551-3437 or Amit Pande at 202-551-3423 if you have questions regarding comments on the financial statements and related matters. Please contact Madeleine Joy Mateo at 202-551-3465 or James Lopez at 202-551-3536 with any other questions. Sincerely, Division of Corporation Finance Office of Finance
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United States securities and exchange commission logo
December 12, 2023
Michael Carotenuto
Chief Financial Officer
Cambridge Bancorp
1336 Massachusetts Avenue
Boston, MA 02138
Re:Cambridge Bancorp
Form 10-K for the year ended December 31, 2022
Form 10-Q for the quarter ended September 30, 2023
File No. 001-38184
Dear Michael Carotenuto:
We have reviewed your filings and have the following comment.
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.
Quarterly Report on Form 10-Q for the quarterly period ended September 30, 2023
Market Risk and Asset Liability Management, page 50
1.We note the statement on page 50 that various reports are "compared to limits established
by the Company’s ALCO policies and appropriate adjustments may be made if the results
are outside the established limits." Please revise future filings to include a materially
complete description of how you seek to manage risks due to changes in interest rates and
other material impacts on your operational facts and circumstances, including any
management or corporate governance controls or procedures for identifying and
responding to rapid changes in interest rates due to or as a result of exogenous or
unknown factors. For example, it is unclear if the 18.9% decrease in the economic value
of equity referenced on page 51 was outside established limits. Please clarify the ALCO-
approved limits and, with a view to disclosure, advise us of the extent to which the ALCO
has approved risk profiles that do not conform to management and Board risk tolerances.
Clarify the extent to which such limits and other policies and controls have been changed
due to the economic and other developments referenced elsewhere.
FirstName LastNameMichael Carotenuto
Comapany NameCambridge Bancorp
December 12, 2023 Page 2
FirstName LastName
Michael Carotenuto
Cambridge Bancorp
December 12, 2023
Page 2
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 Michael Volley at 202-551-3437 or Amit Pande at 202-551-3423 if you
have questions regarding comments on the financial statements and related matters. Please
contact Madeleine Joy Mateo at 202-551-3465 or James Lopez at 202-551-3536 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Finance