SEC Comment Letter for SEACOAST BANKING CORP OF FLORIDA (SBCF) (CIK 0000730708) (SBCF) — Aug 16, 2007
SEACOAST BANKING CORP OF FLORIDA (SBCF) (CIK 0000730708)
Date: Aug. 16, 2007 · CIK: 0000730708 · Accession: 0000000000-07-040316
AI Filing Summary & Sentiment
File numbers found in text: 000-13660
Letter
Mail Stop 4561 August 16, 2007 Mr. William R. Hahl Chief Financial Officer Seacoast Banking Corporation of Florida 815 Colorado Avenue Stuart, FL 34994
RE: Seacoast Banking Corporation of Florida Form 10-K for the Fiscal Ye ar Ended December 31, 2006 Filed March 15, 2007 File No. 000-13660
Dear Mr. Hahl:
We have reviewed your filing and have the following comments. We have limited our review to only your financial stat ements and related disclosures and do not intend to expand our review to other portions of your documents. Please provide a written response to our comments. Please be as detailed as necessary in your explanation. In some of our comments, we may ask you to provide us with information so we may better understand your disclosure. After reviewing this information, we may raise additional comments.
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 comments or any other aspect of our review. Feel free to call us at the telephone numbers listed at the end of this letter.
Form 10-K for the Fiscal Year Ended December 31, 2006
Allowance and Provision for Loan Losses, pages 18-20
1. Please tell us how you adjust from your expected loss model to determine the incurred losses pursuant to SFAS 5. We note that the company discloses that commercial and commercial real estate lo ans are assigned internal risk ratings reflecting the probability of the borrower defaulting on any obligation and the probable loss in the event of default.
Mr. William R.Hahl Seacoast Banking Corporation of Florida August 16, 2007 Page 2
2. Your disclosure in Note A. Significa nt Accounting Policies states that the allowance consists of formula-based co mponents, allowance for impaired loans and allowance related to addi tional factors. Please tell us and disclose in future filings the amount of each of these components.
Please respond to these comments within 10 business days or tell us when you will provide us with a response. Please furnish a letter that keys your responses to our comments and provides any requested inform ation. Detailed cover letters greatly facilitate our review. Please understand th at we may have additional comments after reviewing your responses to our comments.
We urge all persons who are responsible for the accuracy and adequacy of the disclosure in the filings to be certain that the filings include all information required under the Securities Exchange Act of 1934 and that they have provided all information investors require for an informed invest ment decision. Since the company and its management are in possession of all facts re lating to a company’s disclosure, they are responsible for the accuracy and adequacy of the disclosures they have made.
In connection with responding to our comments, please provide, in writing, a statement from the company acknowledging that:
the company is responsible for the adequacy and accuracy of the disclosure in the filing;
staff comments or changes to disclosure in response to staff comments do not foreclose the Commission from taking any action with respect to the filing; and
the company may not assert staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.
In addition, please be advise d that the Division of Enfo rcement has access to all information you provide to the staff of the Divi sion of Corporation Fi nance in our review of your filing or in response to our comments on your filing.
You may contact Chris Harley, Staff Accountant, at (202) 551-3695 or me at (202) 551-3490 if you have questions.
S i n c e r e l y ,
D o n a l d W a l k e r Senior Assistant Chief Accountant
Show Raw Text
Mail Stop 4561
August 16, 2007
Mr. William R. Hahl
Chief Financial Officer
Seacoast Banking Corporation of Florida
815 Colorado Avenue
Stuart, FL 34994
RE: Seacoast Banking Corporation of Florida
Form 10-K for the Fiscal Ye ar Ended December 31, 2006
Filed March 15, 2007
File No. 000-13660
Dear Mr. Hahl:
We have reviewed your filing and have the following comments. We have
limited our review to only your financial stat ements and related disclosures and do not
intend to expand our review to other portions of your documents. Please provide a
written response to our comments. Please be as detailed as necessary in your
explanation. In some of our comments, we may ask you to provide us with information so we may better understand your disclosure. After reviewing this information, we may
raise additional comments.
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 comments or any other aspect of our review. Feel free to call us at the telephone numbers listed at the end of this letter.
Form 10-K for the Fiscal Year Ended December 31, 2006
Allowance and Provision for Loan Losses, pages 18-20
1. Please tell us how you adjust from your expected loss model to determine the
incurred losses pursuant to SFAS 5. We note that the company discloses that
commercial and commercial real estate lo ans are assigned internal risk ratings
reflecting the probability of the borrower defaulting on any obligation and the
probable loss in the event of default.
Mr. William R.Hahl
Seacoast Banking Corporation of Florida
August 16, 2007 Page 2
2. Your disclosure in Note A. Significa nt Accounting Policies states that the
allowance consists of formula-based co mponents, allowance for impaired loans
and allowance related to addi tional factors. Please tell us and disclose in future
filings the amount of each of these components.
Please respond to these comments within 10 business days or tell us when you
will provide us with a response. Please furnish a letter that keys your responses to our comments and provides any requested inform ation. Detailed cover letters greatly
facilitate our review. Please understand th at we may have additional comments after
reviewing your responses to our comments.
We urge all persons who are responsible for the accuracy and adequacy of the
disclosure in the filings to be certain that the filings include all information required under the Securities Exchange Act of 1934 and that they have provided all information
investors require for an informed invest ment decision. Since the company and its
management are in possession of all facts re lating to a company’s disclosure, they are
responsible for the accuracy and adequacy of the disclosures they have made.
In connection with responding to our comments, please provide, in writing, a
statement from the company acknowledging that:
the company is responsible for the adequacy and accuracy of the disclosure in the
filing;
staff comments or changes to disclosure in response to staff comments do not
foreclose the Commission from taking any action with respect to the filing; and
the company may not assert staff comments as a defense in any proceeding initiated
by the Commission or any person under the federal securities laws of the United States.
In addition, please be advise d that the Division of Enfo rcement has access to all
information you provide to the staff of the Divi sion of Corporation Fi nance in our review
of your filing or in response to our comments on your filing.
You may contact Chris Harley, Staff Accountant, at (202) 551-3695 or me at
(202) 551-3490 if you have questions.
S i n c e r e l y ,
D o n a l d W a l k e r
Senior Assistant Chief Accountant