SEC Comment Letter 0000000000-23-014171 to GERMAN AMERICAN BANCORP, INC. (GABC) (CIK 0000714395) (GABC)
GERMAN AMERICAN BANCORP, INC. (GABC) (CIK 0000714395)
Date: Dec. 28, 2023 · CIK: 0000714395 · Accession: 0000000000-23-014171
AI Filing Summary & Sentiment
File numbers found in text: 001-15877
Letter
United States securities and exchange commission logo December 28, 2023 Bradley M. Rust President and Chief Financial Officer German American Bancorp, Inc. 711 Main Street Jasper, IN 47546 Re:German American Bancorp, Inc. Form 10-K for the Fiscal Year Ended December 31, 2022 File No. 001-15877 Dear Bradley M. Rust: We have limited our review of your filing to the financial statements and related disclosures and have the following comment. 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 filed March 1, 2023 Management's Discussion and Analysis of Financial Condition and Results of Operations Loans, page 38 1.We note the disclosure on page 39 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.), if any. 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. 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.
FirstName LastNameBradley M. Rust Comapany NameGerman American Bancorp, Inc. December 28, 2023 Page 2 FirstName LastName Bradley M. Rust German American Bancorp, Inc. December 28, 2023 Page 2 Please contact Lory Empie at 202-551-3714 or Marc Thomas at 202-551-3452 with any questions. Sincerely, Division of Corporation Finance Office of Finance
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United States securities and exchange commission logo
December 28, 2023
Bradley M. Rust
President and Chief Financial Officer
German American Bancorp, Inc.
711 Main Street
Jasper, IN 47546
Re:German American Bancorp, Inc.
Form 10-K for the Fiscal Year Ended December 31, 2022
File No. 001-15877
Dear Bradley M. Rust:
We have limited our review of your filing to the financial statements and related
disclosures and have the following comment.
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 filed March 1, 2023
Management's Discussion and Analysis of Financial Condition and Results of Operations
Loans, page 38
1.We note the disclosure on page 39 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.), if any. 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.
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.
FirstName LastNameBradley M. Rust
Comapany NameGerman American Bancorp, Inc.
December 28, 2023 Page 2
FirstName LastName
Bradley M. Rust
German American Bancorp, Inc.
December 28, 2023
Page 2
Please contact Lory Empie at 202-551-3714 or Marc Thomas at 202-551-3452 with any
questions.
Sincerely,
Division of Corporation Finance
Office of Finance