SEC Comment Letter for ARROW FINANCIAL CORP (AROW) (CIK 0000717538) (AROW) — Mar 16, 2016
ARROW FINANCIAL CORP (AROW) (CIK 0000717538)
Date: March 16, 2016 · CIK: 0000717538 · Accession: 0000000000-16-068552
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 333-210110
Letter
Mailstop 4710 March 15, 2016 Mr. Thomas J. Murphy President, Chief Executive Officer and Director Arrow Financial Corporation 250 Glen Street Glens Falls, NY 12801
Re: Arrow Financial Corporation Registration Statement on Form S-3 Filed March 11, 2016 File No. 333-210110
Dear Mr. Murphy :
This is to advise you that we have not reviewed and will not review your registration statement .
We urge all persons who are responsible for the accuracy and adequacy of the disclosure in the filing to be certain that the filing includes the information the Securities Act of 193 3 and all applicable Securities Act rules require. Since the company and its management are in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy and adequacy of the disclosures they have made.
In the event you request acceleration of the effective date of the pending regist ration statement , please provide a written statement from the company acknowledging that:
should the Commission or the staff, acting pursuant to delegated authority, declare the filing effective, it does not foreclose the Commission from taking any action wit h respect to the filing;
the action of the Commission or the staff, acting pursuant to delegated authority, in declaring the filing effective, does not relieve the company from its full responsibility for the adequacy and accuracy of the disclosure in th e filing; and
the company may not assert staff comments and the declaration of effectiveness as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.
Please refer to Rules 460 and 4 61 regarding requests for acceleration . We will consider a written request for acceleration of the effective date of the registration statement as confirmation
Mr. Thomas J. Murphy Arrow Financial Corporation March 15, 2016 Page 2
of the fact that those requesting acceleration are aware of their respective responsibilities u nder the Securities Act of 1933 and the Securities Exchange Act of 1934 as they relate to the proposed public offering of the registered securities .
Please contact Joshua Dilk , Staff Attorney, at (202) 551 -3427 with any questions.
Sincerely,
/s/ Era Anagnosti
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Mailstop 4710 March 15, 2016 Mr. Thomas J. Murphy President, Chief Executive Officer and Director Arrow Financial Corporation 250 Glen Street Glens Falls, NY 12801 Re: Arrow Financial Corporation Registration Statement on Form S-3 Filed March 11, 2016 File No. 333-210110 Dear Mr. Murphy : This is to advise you that we have not reviewed and will not review your registration statement . We urge all persons who are responsible for the accuracy and adequacy of the disclosure in the filing to be certain that the filing includes the information the Securities Act of 193 3 and all applicable Securities Act rules require. Since the company and its management are in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy and adequacy of the disclosures they have made. In the event you request acceleration of the effective date of the pending regist ration statement , please provide a written statement from the company acknowledging that: should the Commission or the staff, acting pursuant to delegated authority, declare the filing effective, it does not foreclose the Commission from taking any action wit h respect to the filing; the action of the Commission or the staff, acting pursuant to delegated authority, in declaring the filing effective, does not relieve the company from its full responsibility for the adequacy and accuracy of the disclosure in th e filing; and the company may not assert staff comments and the declaration of effectiveness as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States. Please refer to Rules 460 and 4 61 regarding requests for acceleration . We will consider a written request for acceleration of the effective date of the registration statement as confirmation Mr. Thomas J. Murphy Arrow Financial Corporation March 15, 2016 Page 2 of the fact that those requesting acceleration are aware of their respective responsibilities u nder the Securities Act of 1933 and the Securities Exchange Act of 1934 as they relate to the proposed public offering of the registered securities . Please contact Joshua Dilk , Staff Attorney, at (202) 551 -3427 with any questions. Sincerely, /s/ Era Anagnosti Era Anagnosti Legal Branch Chief Office of Financial Services cc: Ms. Michele Kloeppel , Esq.