SEC Comment Letter 0000000000-24-000216 to CAMBRIDGE BANCORP (CIK 0000711772)
CAMBRIDGE BANCORP (CIK 0000711772)
Date: Jan. 5, 2024 · CIK: 0000711772 · Accession: 0000000000-24-000216
AI Filing Summary & Sentiment
File numbers found in text: 001-38184
Referenced dates: December 19, 2023
Letter
United States securities and exchange commission logo January 5, 2024 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 Response dated December 19, 2023 File No. 001-38184 Dear Michael Carotenuto: We have reviewed your December 19, 2023 response to our comment letter 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. Unless we note otherwise, any references to prior comments are to comments in our December 12, 2023 letter. Response Letter dated December 19, 2023 General 1.We note your draft disclosure does not address the use of derivative financial instruments, although page 91 of the Form 10-K indicates that you use derivatives to manage interest rate and other economic risks. Please revise your draft disclosure to further clarify whether and how derivative financial instruments are used to manage economic risks, including whether the simulation and EVE model outputs reflect such use of derivatives.
FirstName LastNameMichael Carotenuto Comapany NameCambridge Bancorp January 5, 2024 Page 2 FirstName LastName Michael Carotenuto Cambridge Bancorp January 5, 2024 Page 2 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
January 5, 2024
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
Response dated December 19, 2023
File No. 001-38184
Dear Michael Carotenuto:
We have reviewed your December 19, 2023 response to our comment letter 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. Unless
we note otherwise, any references to prior comments are to comments in our December 12,
2023 letter.
Response Letter dated December 19, 2023
General
1.We note your draft disclosure does not address the use of derivative financial instruments,
although page 91 of the Form 10-K indicates that you use derivatives to manage interest
rate and other economic risks. Please revise your draft disclosure to further clarify
whether and how derivative financial instruments are used to manage economic risks,
including whether the simulation and EVE model outputs reflect such use of derivatives.
FirstName LastNameMichael Carotenuto
Comapany NameCambridge Bancorp
January 5, 2024 Page 2
FirstName LastName
Michael Carotenuto
Cambridge Bancorp
January 5, 2024
Page 2
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