SEC Comment Letter for RENASANT CORP (RNST) (CIK 0000715072) (RNST) — May 9, 2018
RENASANT CORP (RNST) (CIK 0000715072)
Date: May 9, 2018 · CIK: 0000715072 · Accession: 0000000000-18-014412
AI Filing Summary & Sentiment
File numbers found in text: 000-13253
Letter
Mail Stop 4720 May 2 , 2018 Kevin D. Chapman Executive Vice President and Chief Financial Officer Renasant Corporation 209 Troy Street Tupelo, Mississippi 38804 -4827
Re: Renasant Corporation Form 10 -K for the Fis cal Year Ended December 31, 2017 Filed February 28, 2018 File No. 000-13253
Dear Mr. Chapman :
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 busine ss days by providing the requested information or advis e 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 Fis cal Year Ended December 31, 2017
Item 7. Management’s Discussion and Analysis of Financial Condition and Results of Operation
Net Interest Income, page 51
1. We note your disclosure on pages 51 and 52 of the non -GAAP measures :
taxable equivalent net interest income , adjusted, net interest margin, adjusted taxable equivalent interest income on loans, adjusted, and taxable equivalent loan yield, adjusted.
These measures exclud e the accretable yield recognized on purchased loans. It appears that disclosing financial measures and metrics excluding the impact of purchase
Kevin D. Chapman Renasant Corporation May 2 , 2018 Page 2
accounting represents an individually tailored recognition and measurement method which could result in a misleading financial metric that violates Rule 100(b) of Regulation G. Please refer to Question 100.04 of the Compliance and Disclosure Interpretations for guidance. Therefore, in future filings, including Forms 8 -K, please do not disclose financial measures and metrics that exclude the impact of purchase accou nting.
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 William Schroeder, Staff Accou ntant, at (202) 551 -3294 or me at (202) 551-3437 with any questions.
Sincerely,
/s/ Michael Volley
Show Raw Text
Mail Stop 4720
May 2 , 2018
Kevin D. Chapman
Executive Vice President and Chief Financial Officer
Renasant Corporation
209 Troy Street
Tupelo, Mississippi 38804 -4827
Re: Renasant Corporation
Form 10 -K for the Fis cal Year Ended December 31, 2017
Filed February 28, 2018
File No. 000-13253
Dear Mr. Chapman :
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 busine ss days by providing the requested
information or advis e 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 Fis cal Year Ended December 31, 2017
Item 7. Management’s Discussion and Analysis of Financial Condition and Results of Operation
Net Interest Income, page 51
1. We note your disclosure on pages 51 and 52 of the non -GAAP measures :
taxable equivalent net interest income , adjusted,
net interest margin, adjusted
taxable equivalent interest income on loans, adjusted, and
taxable equivalent loan yield, adjusted.
These measures exclud e the accretable yield recognized on purchased loans. It appears
that disclosing financial measures and metrics excluding the impact of purchase
Kevin D. Chapman
Renasant Corporation
May 2 , 2018
Page 2
accounting represents an individually tailored recognition and measurement method
which could result in a misleading financial metric that violates Rule 100(b) of
Regulation G. Please refer to Question 100.04 of the Compliance and Disclosure
Interpretations for guidance. Therefore, in future filings, including Forms 8 -K, please do
not disclose financial measures and metrics that exclude the impact of purchase
accou nting.
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 William Schroeder, Staff Accou ntant, at (202) 551 -3294 or me at (202)
551-3437 with any questions.
Sincerely,
/s/ Michael Volley
Michael Volley
Staff Accountant
Office of Financial Services