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SEC Comment Letter for ARROW FINANCIAL CORP (AROW) (CIK 0000717538) (AROW) — Aug 3, 2006

ARROW FINANCIAL CORP (AROW) (CIK 0000717538)
Date: Aug. 3, 2006 · CIK: 0000717538 · Accession: 0000000000-06-036539

AI Filing Summary & Sentiment

Sentiment
Urgency
Document Type
Confidence
SEC Posture
Company Posture

Summary

Reasoning

File numbers found in text: 000-12507

Date
August 3, 2006
Author
Paul Cline
Form
UPLOAD
Company
ARROW FINANCIAL CORP (AROW) (CIK 0000717538)

Letter

Mail Stop 4561 August 3, 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 31, 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. We con tinue to believe the errors noted are material, and your financial statements should be restated to re flect the correction of the errors. Please restate your financ ial statements in response to this comment.

* * *

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 intended revisions prior to filing the amendment. Detailed cover letters greatly facilitate our review. Please file

Mr. John J. Murphy Arrow Financial Corporation August 3, 2006 Page 2

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

Show Raw Text
Mail Stop 4561
        August 3, 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 31, 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.  We con tinue to believe the errors noted are
material, and your financial statements should be restated to re flect the correction
of the errors.  Please restate your financ ial statements in response to this
comment.

* * *

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 intended revisions prior
to filing the amendment.  Detailed cover letters  greatly facilitate our review.  Please file

Mr. John J. Murphy
Arrow Financial Corporation
August 3, 2006 Page 2

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