SEC Comment Letter for FIRST COMMONWEALTH FINANCIAL (FCF) — Sep 23, 2014
FIRST COMMONWEALTH FINANCIAL CORP /PA/ (FCF) (CIK 0000712537)
Date: Sept. 23, 2014 · CIK: 0000712537 · Accession: 0000000000-14-047696
AI Filing Summary & Sentiment
File numbers found in text: 001-11138
Letter
UNITED STATES SECURITIES AND EXCHANGE COMMISSION WASHINGTON, D.C. 20549 -3561 September 23, 2014 Via E -mail T. Michael Price President and Chief Executive Officer First Commonwealth Financial Corp 601 Philadelphia Street Indiana, PA 15701
Re: First Commonwealth Financial Corp Form 10 -K for the fiscal ye ar ended December 31, 2013 Filed March 3 , 2014 File No. 001-11138
Dear Mr. Price :
We have reviewed your filing s and have the following comments. 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 letter within ten business days by providing the requested informati on or by advising us when you will provide the requested response. If you do not believe our comments apply to your facts and circumstance s, please tell us why in your response.
After reviewing the information you provide in response to these comments, we may have additional comments.
Item1. Business
1. In future filings provide a narrative discussion of each category in your loan portfolio including:
the composition of each loan category; any risks that are unique to each category; a brief description of your underwriting criteria for each category (including subcategories such as indirect auto lending) and whether you engage in subprime lending.
Please provide us with a draft of your proposed disclosure.
T. Michael Price First Commonwealth Financial Corp September 23 , 2014 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 compa ny 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 responding to our comments, please provide a written statement from the co mpany 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.
Please contact Jessica Livingston, Staff Attorney, at 202 -551-3448 or me at 202 -551- 3491 with any other questions.
Sincerely,
/s/ Todd K. Schiffman
Show Raw Text
UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549 -3561
September 23, 2014
Via E -mail
T. Michael Price
President and Chief Executive Officer
First Commonwealth Financial Corp
601 Philadelphia Street
Indiana, PA 15701
Re: First Commonwealth Financial Corp
Form 10 -K for the fiscal ye ar ended December 31, 2013
Filed March 3 , 2014
File No. 001-11138
Dear Mr. Price :
We have reviewed your filing s and have the following comments. 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 letter within ten business days by providing the requested
informati on or by advising us when you will provide the requested response. If you do not
believe our comments apply to your facts and circumstance s, please tell us why in your
response.
After reviewing the information you provide in response to these comments, we may
have additional comments.
Item1. Business
1. In future filings provide a narrative discussion of each category in your loan portfolio
including:
the composition of each loan category;
any risks that are unique to each category;
a brief description of your underwriting criteria for each category (including
subcategories such as indirect auto lending) and
whether you engage in subprime lending.
Please provide us with a draft of your proposed disclosure.
T. Michael Price
First Commonwealth Financial Corp
September 23 , 2014
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 compa ny 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 responding to our comments, please provide a written statement from the co mpany
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.
Please contact Jessica Livingston, Staff Attorney, at 202 -551-3448 or me at 202 -551-
3491 with any other questions.
Sincerely,
/s/ Todd K. Schiffman
Todd K. Schiffman
Assistant Director