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SEC Comment Letter for VALLEY NATIONAL BANCORP (VLY, VLYPN, VLYPO, VLYPP) (CIK 0000714310) (VLY) — Jun 3, 2022

VALLEY NATIONAL BANCORP (VLY, VLYPN, VLYPO, VLYPP) (CIK 0000714310)
Date: June 3, 2022 · CIK: 0000714310 · Accession: 0000000000-22-006028

AI Filing Summary & Sentiment

Date
June 3, 2022
Author
Office of Finance
Form
UPLOAD
Company
VALLEY NATIONAL BANCORP (VLY, VLYPN, VLYPO, VLYPP) (CIK 0000714310)

Letter

United States securities and exchange commission logo June 3, 2022 Ira Robbins Chief Executive Officer Valley National Bancorp One Penn Plaza New York, NY 10119 Re:VALLEY NATIONAL BANCORP Dear Mr. Robbins: We have limited our review of your filing to the financial statements and related disclosures and have the following comment. In our comment, we may ask you to provide us with information so we may better understand your disclosure. Please respond to this comment 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 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 period ending December 31, 2021 Selected Performance Indicators, page 43 1.We note that you disclose net income, as adjusted, total non-interest expense, as adjusted, total non-interest income, as adjusted and gross operating income, as adjusted. These adjusted measures appear to be non-GAAP measures. Please address the following in future filings:

•Identify and label these measures as non-GAAP as required by Item 10(e)(1)(i) of Regulation S-K and provide all the disclosures in Item 10(e)(1)(i)(A-D) related to all non-GAAP indicators; •Identify net interest income in your gross operating income reconciliation as a GAAP measure, “as reported”, consistent with your other non-GAAP disclosures; and; •Consider including a separate 'non-GAAP' section in future filings that houses all non-GAAP disclosures included in the document.

FirstName LastNameIra Robbins Comapany NameValley National Bancorp June 3, 2022 Page 2 FirstName LastName Ira Robbins Valley National Bancorp June 3, 2022 Page 2 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. You may contact Michelle Miller at 202-551-3368 or David Irving at 202-551-3321 with any questions. Sincerely, Division of Corporation Finance Office of Finance

Show Raw Text
United States securities and exchange commission logo
June 3, 2022
Ira Robbins
Chief Executive Officer
Valley National Bancorp
One Penn Plaza
New York, NY 10119
Re:VALLEY NATIONAL BANCORP
Dear Mr. Robbins:
            We have limited our review of your filing to the financial statements and related
disclosures and have the following comment.  In our comment, we may ask you to provide us
with information so we may better understand your disclosure.
            Please respond to this comment 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 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 period ending December 31, 2021
Selected Performance Indicators, page 43
1.We note that you disclose net income, as adjusted, total non-interest expense, as adjusted,
total non-interest income, as adjusted and gross operating income, as adjusted.  These
adjusted measures appear to be non-GAAP measures.  Please address the following in
future filings:

•Identify and label these measures as non-GAAP as required by Item 10(e)(1)(i) of
Regulation S-K and provide all the disclosures in Item 10(e)(1)(i)(A-D) related to all
non-GAAP indicators;
•Identify net interest income in your gross operating income reconciliation  as a
GAAP measure, “as reported”, consistent with your other non-GAAP disclosures;
and;
•Consider including a separate 'non-GAAP' section in future filings that houses all
non-GAAP disclosures included in the document.

 FirstName LastNameIra  Robbins
 Comapany NameValley National Bancorp
 June 3, 2022 Page 2
 FirstName LastName
Ira  Robbins
Valley National Bancorp
June 3, 2022
Page 2
            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.
            You may contact Michelle Miller at 202-551-3368 or David Irving at 202-551-3321 with
any questions.
Sincerely,
Division of Corporation Finance
Office of Finance