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
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File numbers found in text: 000-12507
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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