SEC Comment Letter for FIRST MERCHANTS CORP (FRME, FRMEP) (CIK 0000712534) (FRME) — Jun 28, 2016
FIRST MERCHANTS CORP (FRME, FRMEP) (CIK 0000712534)
Date: June 28, 2016 · CIK: 0000712534 · Accession: 0000000000-16-082404
AI Filing Summary & Sentiment
Letter
Mail Stop 4720 June 28, 2016 Mr. Mark K. Hardwick Chief Financial Officer First Merchants Corporation 200 East Jackson Street Muncie, IN 47305 -2814
Re: First Merchants Corporation Form 10-K for the Fiscal Year Ended December 31, 2015 Filed February 29, 2016 File No. 000 -17071
Dear Mr. Hardwick :
We have limited our review of your filing to the financial statements and related disclosures and have the following comment . In some of our comments, we may ask you to provide us with information so we may better understand your disclosure.
Please respond to this comment within ten busine ss days by providing the requested information or advis e us as soon as possible when you will respond. If you do not believe our comment applies to your facts and circumstances, please tell us why in your response.
After reviewing your response to this comment , we may have additional comments.
Form 10 -K for the Fiscal Year Ended D ecember 31, 2015
Item 6. Selected Financial Data
Per Share Data, page 29
Capital, page 36
1. Please disclose how your non -GAAP financial measures provide useful information to investors regarding your financial condition and results of operations in futu re filings. Please refer to Item 10 (e) (1) (i) (C) of Regulation S -K.
Mr. Mark K. Hardwick First Merchants Corporation June 28, 2016 Page 2
We urge all persons who are responsible for the accuracy and adequacy of the disclosure in the filing to be certain that the filing includes the information the Securities Exchange Act of 1934 and all applicable Exchange Act rules require. Since the company and its management are in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy and adequacy of t he disclosures they have made.
In responding to our comment , please provide a written statement from the company acknowledging that:
the company is responsible for the adequacy and accuracy of the disclosure in the filing;
staff comments or changes t o disclosure in response to staff comments do not foreclose the Commission from taking any action with respect to the filing; and
the company may not assert staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.
You may contact Chris Harley at (202) 551 -3695 or me at (202) 551 -3492 with any questions.
Sincerely,
/s/ John P. Nolan
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Mail Stop 4720 June 28, 2016 Mr. Mark K. Hardwick Chief Financial Officer First Merchants Corporation 200 East Jackson Street Muncie, IN 47305 -2814 Re: First Merchants Corporation Form 10-K for the Fiscal Year Ended December 31, 2015 Filed February 29, 2016 File No. 000 -17071 Dear Mr. Hardwick : We have limited our review of your filing to the financial statements and related disclosures and have the following comment . In some of our comments, we may ask you to provide us with information so we may better understand your disclosure. Please respond to this comment within ten busine ss days by providing the requested information or advis e us as soon as possible when you will respond. If you do not believe our comment applies to your facts and circumstances, please tell us why in your response. After reviewing your response to this comment , we may have additional comments. Form 10 -K for the Fiscal Year Ended D ecember 31, 2015 Item 6. Selected Financial Data Per Share Data, page 29 Capital, page 36 1. Please disclose how your non -GAAP financial measures provide useful information to investors regarding your financial condition and results of operations in futu re filings. Please refer to Item 10 (e) (1) (i) (C) of Regulation S -K. Mr. Mark K. Hardwick First Merchants Corporation June 28, 2016 Page 2 We urge all persons who are responsible for the accuracy and adequacy of the disclosure in the filing to be certain that the filing includes the information the Securities Exchange Act of 1934 and all applicable Exchange Act rules require. Since the company and its management are in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy and adequacy of t he disclosures they have made. In responding to our comment , please provide a written statement from the company acknowledging that: the company is responsible for the adequacy and accuracy of the disclosure in the filing; staff comments or changes t o disclosure in response to staff comments do not foreclose the Commission from taking any action with respect to the filing; and the company may not assert staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States. You may contact Chris Harley at (202) 551 -3695 or me at (202) 551 -3492 with any questions. Sincerely, /s/ John P. Nolan John P. Nolan Senior Assistant Chief Accountant Office o f Financial Services