SEC Comment Letter 0000000000-24-013655 to ACNB CORP (ACNB) (CIK 0000715579) (ACNB)
ACNB CORP (ACNB) (CIK 0000715579)
Date: Dec. 11, 2024 · CIK: 0000715579 · Accession: 0000000000-24-013655
AI Filing Summary & Sentiment
File numbers found in text: 001-35015
Letter
December 11, 2024 Jason H. Weber Chief Financial Officer ACNB Corporation 16 Lincoln Square Gettysburg, PA 17325 Re:ACNB Corporation Form 8-K Filed October 24, 2024 File No. 001-35015 Dear Jason H. Weber: 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 8-K Filed October 24, 2024 Exhibit 99.1 1.We note your presentation of “Tangible equity (excluding AOCI)” and “Tangible book value per share (excluding AOCI),” both of which exclude the impact of accumulated other comprehensive loss and represent individually tailored accounting measures given that the adjustment to exclude accumulated other comprehensive loss has the effect of changing the recognition and measurement principles required to be applied in accordance with GAAP. Therefore, please remove the presentation of these non-GAAP measures from your future filings. Refer to Question 100.04 of the Division of Corporation Finance’s Compliance & Disclosure Interpretations on Non- GAAP Financial Measures and Rule 100(b) of Regulation G. 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.
December 11, 2024 Page 2 Please contact Katharine Garrett at 202-551-2332 or John Spitz at 202-551-3484 with any questions. Sincerely, Division of Corporation Finance Office of Finance
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December 11, 2024
Jason H. Weber
Chief Financial Officer
ACNB Corporation
16 Lincoln Square
Gettysburg, PA 17325
Re:ACNB Corporation
Form 8-K Filed October 24, 2024
File No. 001-35015
Dear Jason H. Weber:
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 8-K Filed October 24, 2024
Exhibit 99.1
1.We note your presentation of “Tangible equity (excluding AOCI)” and “Tangible
book value per share (excluding AOCI),” both of which exclude the impact of
accumulated other comprehensive loss and represent individually tailored accounting
measures given that the adjustment to exclude accumulated other comprehensive loss
has the effect of changing the recognition and measurement principles required to be
applied in accordance with GAAP. Therefore, please remove the presentation of these
non-GAAP measures from your future filings. Refer to Question 100.04 of the
Division of Corporation Finance’s Compliance & Disclosure Interpretations on Non-
GAAP Financial Measures and Rule 100(b) of Regulation G.
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.
December 11, 2024
Page 2
Please contact Katharine Garrett at 202-551-2332 or John Spitz at 202-551-3484 with
any questions.
Sincerely,
Division of Corporation Finance
Office of Finance