SEC Comment Letter for FIRST MERCHANTS CORP (FRME, FRMEP) (CIK 0000712534) (FRME) — Jul 9, 2007
FIRST MERCHANTS CORP (FRME, FRMEP) (CIK 0000712534)
Date: July 9, 2007 · CIK: 0000712534 · Accession: 0000000000-07-033205
AI Filing Summary & Sentiment
File numbers found in text: 000-17071
Letter
June 18, 2007 By U.S. Mail and facsimile to (765) 751-1897. Mark K. Hardwick Chief Financial Officer First Merchants Corporation 200 East Jackson Street Muncie, IN 47305
Re: First Merchants Corporation Form 10-K for Fiscal Year Ended December 31, 2006 Filed March 16, 2007 File No. 000-17071
Dear Mr. Hardwick:
We have reviewed your response filed with the Commission on May 25, 2007 and have the following additional comments. Where indicated, we think you should revise your document in response to these comments in future filings. If you disagree, we will consider your explanation as to why our co mments are inapplicable or a revision is unnecessary. Please be as detaile d as necessary in your explan ation. In our comment, we may ask you to provide us with supplemental information so we may better understand your disclosure. After reviewing this information, we may or may not raise additional comments.
Please understand that the purpose of our re view process is to assist you in your compliance with the applicable disclosure requirements and to enhance the overall disclosure in your filing. We look forward to working with you in these respects. We welcome any questions you may have about our comments or any other aspect of our review. Feel free to call us at the telephone numbers listed at the end of this letter.
Note 1, Nature of Operations and Summary of Significant Accounting Policies, page 25
1. We note that you have proposed to disc lose your self-insur ance risk on a per policy basis. Please revise to disclose the total exposure rela ted to self-insurance for all policies outstanding.
Mark K. Hardwick First Merchants Corporation June 18, 2007 Page 2 2. Please revise to disclose how you account for the intercompany transactions related to the self-insurance that First Merchant’s Reinsurance Company provides to its parent or ot her related entities.
Note 22, Derivative Instruments and Hedging Activities, page 52
3. Please revise to disclose the methods and significant assumptions used to determine the fair value of your derivative instruments.
4. We note in your response that your interest rate floors ha ve strike rates that range from 6.0% to 7.5%. Please revise to disclose the total notional amounts associated with each strike rate.
* * * * *
Please respond to these comments within 10 business days or tell us when you will provide us with a response. Please furnish a cover letter that keys your response to our comments, indicates your in tent to include the requested revisions in your future filings and provides any requested supplemen tal information. Please provide us with your proposed disclosures. Please understa nd that we may have additional comments after reviewing your responses to our comments.
You may contact Rebekah M oore, Staff Accountant, at (202) 551-3463 or me at (202) 551-3494 if you have questions.
Sincerely,
Kevin W. Vaughn
Branch Chief
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Mail Stop 4561 June 18, 2007 By U.S. Mail and facsimile to (765) 751-1897. Mark K. Hardwick Chief Financial Officer First Merchants Corporation 200 East Jackson Street Muncie, IN 47305 Re: First Merchants Corporation Form 10-K for Fiscal Year Ended December 31, 2006 Filed March 16, 2007 File No. 000-17071 Dear Mr. Hardwick: We have reviewed your response filed with the Commission on May 25, 2007 and have the following additional comments. Where indicated, we think you should revise your document in response to these comments in future filings. If you disagree, we will consider your explanation as to why our co mments are inapplicable or a revision is unnecessary. Please be as detaile d as necessary in your explan ation. In our comment, we may ask you to provide us with supplemental information so we may better understand your disclosure. After reviewing this information, we may or may not raise additional comments. Please understand that the purpose of our re view process is to assist you in your compliance with the applicable disclosure requirements and to enhance the overall disclosure in your filing. We look forward to working with you in these respects. We welcome any questions you may have about our comments or any other aspect of our review. Feel free to call us at the telephone numbers listed at the end of this letter. Note 1, Nature of Operations and Summary of Significant Accounting Policies, page 25 1. We note that you have proposed to disc lose your self-insur ance risk on a per policy basis. Please revise to disclose the total exposure rela ted to self-insurance for all policies outstanding. Mark K. Hardwick First Merchants Corporation June 18, 2007 Page 2 2. Please revise to disclose how you account for the intercompany transactions related to the self-insurance that First Merchant’s Reinsurance Company provides to its parent or ot her related entities. Note 22, Derivative Instruments and Hedging Activities, page 52 3. Please revise to disclose the methods and significant assumptions used to determine the fair value of your derivative instruments. 4. We note in your response that your interest rate floors ha ve strike rates that range from 6.0% to 7.5%. Please revise to disclose the total notional amounts associated with each strike rate. * * * * * Please respond to these comments within 10 business days or tell us when you will provide us with a response. Please furnish a cover letter that keys your response to our comments, indicates your in tent to include the requested revisions in your future filings and provides any requested supplemen tal information. Please provide us with your proposed disclosures. Please understa nd that we may have additional comments after reviewing your responses to our comments. You may contact Rebekah M oore, Staff Accountant, at (202) 551-3463 or me at (202) 551-3494 if you have questions. Sincerely, Kevin W. Vaughn Branch Chief