SEC Comment Letter for COMMUNITY BANK SYSTEM, INC. (CBU) (CIK 0000723188) (CBU) — Jan 2, 2020
COMMUNITY BANK SYSTEM, INC. (CBU) (CIK 0000723188)
Date: Jan. 2, 2020 · CIK: 0000723188 · Accession: 0000000000-20-000002
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File numbers found in text: 333-235696
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December 31, 2019
Mark E. Tryniski
President and Chief Executive Officer
Community Bank System, Inc.
5790 Widewaters Parkway
DeWitt, NY 13214
Re:Community Bank System, Inc.
Registration Statement on Form S-4
Filed December 23, 2019
File No. 333-235696
Dear Mr. Tryniski:
This is to advise you that we have not reviewed and will not review your registration
statement.
Please refer to Rules 460 and 461 regarding requests for acceleration. 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.
Please contact David Gessert at 202-551-2326 with any questions.
Sincerely,
Division of Corporation Finance
Office of Finance