SEC Comment Letter for FIRST COMMONWEALTH FINANCIAL (FCF) — Oct 31, 2006
FIRST COMMONWEALTH FINANCIAL CORP /PA/ (FCF) (CIK 0000712537)
Date: Oct. 31, 2006 · CIK: 0000712537 · Accession: 0000000000-06-053045
AI Filing Summary & Sentiment
File numbers found in text: 001-11138
Letter
March 28, 2006 By U.S. Mail and facsimile to (724) 464-1112 Mr. John J. Dolan Executive Vice President and Chief Financial Officer First Commonwealth Financial Corporation 22 N. Sixth Street Indiana, PA 15701
Re: First Commonwealth Financial Corporation Item 4.01 Form 8-K Filed March 27, 2006 File No. 001-11138
Dear Mr. Dolan:
We have reviewed your filing and have the following comment. Where indicated, we think you should revise your document in response to this comment. If you disagree, we will consider your explanation as to why our comment is inapplicable or a revision is unnecessary. Please be as detailed as necessary in your explanation. After reviewing this information, we may raise additional comments.
Please understand that the purpose of our review 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 comment or any other aspect of our review. Feel free to call us at the telephone numbers listed at the end of this letter.
1. Please amend your Form 8-K to state if you consulted with your newly engaged auditor during the two most recent years, and any subsequent interim period prior to engaging your new auditor. Refer to Item 3.04(a)(2) of Regulation S-K. * * * * *
As appropriate, please amend your filing and respond to this comment within five business days or tell us when you will respond. You may wish to provide us with marked copies of the amendment to expedite our review. Please furnish a cover letter with your amendment that keys your responses to our comment and provides any requested information. Detailed cover letters greatly facilitate our review. Please understand that we may have additional comments after reviewing your amendment and responses to our comment.
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 all information required under the Securities Exchange Act of 1934 and that they have provided all information investors require for
an informed investment decision. 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 the disclosures they have made.
In connection with responding to our comment, please provide, in writing, a 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 to 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.
In addition, please be advised that the Division of Enforcement has access to all information you provide to the staff of the Division of Corporation Finance in our review of your filing or in response to our comment on your filing.
If you have any questions, please call me at (202) 551-3781.
Sincerely,
Matthew Komar
Staff Accountant
Show Raw Text
Mail Stop 4561
March 28, 2006
By U.S. Mail and facsimile to (724) 464-1112
Mr. John J. Dolan
Executive Vice President and
Chief Financial Officer
First Commonwealth Financial Corporation
22 N. Sixth Street
Indiana, PA 15701
Re: First Commonwealth Financial Corporation
Item 4.01 Form 8-K
Filed March 27, 2006
File No. 001-11138
Dear Mr. Dolan:
We have reviewed your filing and have the following comment.
Where indicated, we think you should revise your document in response to this comment. If you disagree, we will consider your explanation as to why our comment is inapplicable or a revision is unnecessary. Please be as detailed as necessary in your explanation. After reviewing this
information, we may raise additional comments.
Please understand that the purpose of our review 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 comment or any other aspect of our review. Feel free to call us at the telephone numbers listed at the end of this letter.
1. Please amend your Form 8-K to state if you consulted with your newly engaged auditor during the two most recent years, and any subsequent interim period prior to engaging your new auditor. Refer to Item 3.04(a)(2) of Regulation S-K.
* * * * *
As appropriate, please amend your filing and respond to this comment within five business days or tell us when you will respond. You may wish to provide us with marked copies of the amendment to expedite our review. Please furnish a cover letter with your amendment that keys your responses to our comment and provides any requested
information. Detailed cover letters greatly facilitate our review.
Please understand that we may have additional comments after reviewing your amendment and responses to our comment.
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 all information required under the Securities Exchange Act of 1934 and that they have provided all information investors require for
an informed investment decision. 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 the disclosures they
have made.
In connection with responding to our comment, please provide, in
writing, a 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 to 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.
In addition, please be advised that the Division of Enforcement has access to all information you provide to the staff of the Division of Corporation Finance in our review of your filing or in response to our comment on your filing.
If you have any questions, please call me at (202) 551-3781.
Sincerely,
Matthew Komar
Staff Accountant