SEC Comment Letter 0000000000-23-013383 to ConnectOne Bancorp, Inc. (CNOB, CNOBP) (CIK 0000712771) (CNOB)
ConnectOne Bancorp, Inc. (CNOB, CNOBP) (CIK 0000712771)
Date: Dec. 7, 2023 · CIK: 0000712771 · Accession: 0000000000-23-013383
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File numbers found in text: 001-40751
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United States securities and exchange commission logo
December 7, 2023
William S. Burns
Senior Executive Vice President & Chief Financial Officer
ConnectOne Bancorp, Inc.
301 Sylvan Avenue
Englewood Cliffs, NJ 07632
Re:ConnectOne Bancorp, Inc.
Form 10-K for the Fiscal Year Ended December 31, 2022
Filed February 24, 2023
File No. 001-40751
Dear William S. Burns:
We have limited our review of your filing to the financial statements and related
disclosures and have the following comments.
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.
Form 10-K for the Fiscal Year Ended December 31, 2022
Management's Discussion and Analysis of Financial Condition and Results of Operations
Loan Portfolio, page 39
1.We note the tabular disclosure on page 40 detailing the composition of your gross loan
portfolio, which includes commercial real estate (“CRE”). Given the significance of CRE
in your total loan portfolio, please revise your disclosures, in future filings, to further
disaggregate the composition of your CRE loan portfolio by separately presenting owner
and non-owner occupied, by borrower type (e.g., by office, hotel, multifamily, etc.),
geographic concentrations and other characteristics (e.g., current weighted average and/or
range of loan-to-value ratios, occupancy rates, etc.) material to an investor’s
understanding of your CRE loan portfolio. In addition, revise to describe the specific
details of any risk management policies, procedures or other actions undertaken by
management in response to the current environment.
Deposits, page 49
FirstName LastNameWilliam S. Burns
Comapany NameConnectOne Bancorp, Inc.
December 7, 2023 Page 2
FirstName LastName
William S. Burns
ConnectOne Bancorp, Inc.
December 7, 2023
Page 2
2.Please revise future filings to disclose the information required by Item 1406(e) of
Regulation S-K, or tell us where this information is disclosed within the Management’s
Discussion and Analysis of Financial Condition and Results of Operations.
3.We note on page 91 that you held $935 million of nonreciprocal brokered time deposits as
of December 31, 2022, compared to $215 million as of December 31, 2021. To the extent
material, please revise future filings to provide additional quantitative and qualitative
information explaining any material changes in the composition of your deposit base, such
as increased reliance on brokered deposits including reciprocal deposit services, and the
related impact on your funding costs and liquidity. In addition, discuss any factors driving
such an increase in utilizing brokered deposits as a source of funding, and related impacts,
if any, that brokered deposits have had on your interest expense, net interest income and
deposit beta.
In closing, we remind you that the company and its management are responsible for the
accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or
absence of action by the staff.
Please contact Jee Yeon Ahn at 202-551-3673 or Robert Klein at 202-551-3847 with any
questions.
Sincerely,
Division of Corporation Finance
Office of Finance