SEC Comment Letter for ARROW FINANCIAL CORP (AROW) (CIK 0000717538) (AROW) — Jul 18, 2006
ARROW FINANCIAL CORP (AROW) (CIK 0000717538)
Date: July 18, 2006 · CIK: 0000717538 · Accession: 0000000000-06-033363
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 000-12507
Letter
Mail Stop 4561 July 18, 2006 By U.S. Mail and Facsimile to (518) 745-5513 Mr. John J. Murphy Chief Financial Officer Arrow Financial Corporation 250 Glen Street Glens Falls, New York 12801
Re: Arrow Financial Corporation Form 10-K for Fiscal Year Ended December 31, 2005 Filed March 14, 2006 File No. 000-12507
Dear Mr. Murphy:
We have reviewed your response filed on July 11, 2006, and have the following additional comment. Please amend your f ilings in response to our comment.
Please understand that the purpose of our re view process is to assist you in your compliance with the applicable disclosure requirements and to enhance the overall disclosure in your filing. We look forward to working with you in these respects. We welcome any questions you may have about our comment or any other aspect of our review. Feel free to call us at the telephone numbers listed at the end of this letter.
Consolidated Statement of Cash Flows, page 55 1. Please refer to prior comment 1. It appears to us that the amounts are material to your cash flows. Please provide us the SAB 99 analysis performed to determine that a restatement is not necessary. Otherwise, please revise your financial statements to reclassify the amounts w ithin the statements of cash flows and report the reclassifications as a correction of an error.
* * *
As applicable, please file your amendment in response to this comment within 10 business days or tell us when you will file the amendment. Please furnish a cover letter with your amendment that keys your res ponse to our comment and provides any requested information. You may wish to provide us drafts of the intend revisions prior to
Mr. John J. Murphy Arrow Financial Corporation July 18, 2006 Page 2
filing the amendment. Detailed cover letters greatly facilitate our re view. Please file your response via EDGAR. Please understand that we may have additional comments after reviewing your amendment and response to our comment.
You may contact Margaret Fitzgerald, Staff Accountant, at (202) 551-3556 or me at (202) 551-3851 if you have questions regard ing this comment and related matters.
Sincerely,
Paul Cline
Senior Accountant
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Mail Stop 4561
July 18, 2006
By U.S. Mail and Facsimile to (518) 745-5513
Mr. John J. Murphy
Chief Financial Officer
Arrow Financial Corporation
250 Glen Street
Glens Falls, New York 12801
Re: Arrow Financial Corporation
Form 10-K for Fiscal Year Ended December 31, 2005
Filed March 14, 2006
File No. 000-12507
Dear Mr. Murphy:
We have reviewed your response filed on July 11, 2006, and have the following
additional comment. Please amend your f ilings in response to our comment.
Please understand that the purpose of our re view process is to assist you in your
compliance with the applicable disclosure requirements and to enhance the overall
disclosure in your filing. We look forward to working with you in these respects. We
welcome any questions you may have about our comment or any other aspect of our
review. Feel free to call us at the telephone numbers listed at the end of this letter.
Consolidated Statement of Cash Flows, page 55
1. Please refer to prior comment 1. It appears to us that the amounts are material to
your cash flows. Please provide us the SAB 99 analysis performed to determine
that a restatement is not necessary. Otherwise, please revise your financial
statements to reclassify the amounts w ithin the statements of cash flows and
report the reclassifications as a correction of an error.
* * *
As applicable, please file your amendment in response to this comment within 10
business days or tell us when you will file the amendment. Please furnish a cover letter with your amendment that keys your res ponse to our comment and provides any
requested information. You may wish to provide us drafts of the intend revisions prior to
Mr. John J. Murphy
Arrow Financial Corporation
July 18, 2006 Page 2
filing the amendment. Detailed cover letters greatly facilitate our re view. Please file
your response via EDGAR. Please understand that we may have additional comments
after reviewing your amendment and response to our comment.
You may contact Margaret Fitzgerald, Staff Accountant, at (202) 551-3556 or me
at (202) 551-3851 if you have questions regard ing this comment and related matters.
Sincerely,
Paul Cline
Senior Accountant