SEC Comment Letter for SEACOAST BANKING CORP OF FLORIDA (SBCF) (CIK 0000730708) (SBCF) — Apr 17, 2009
SEACOAST BANKING CORP OF FLORIDA (SBCF) (CIK 0000730708)
Date: April 17, 2009 · CIK: 0000730708 · Accession: 0000000000-09-020294
AI Filing Summary & Sentiment
File numbers found in text: 000-13660
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DIVISION OF CORPORATION FINANCE UNITED STATES SECURITIES AND EXCHANGE COMMISSION WASHINGTON, D.C. 20549 April 17, 2009 Dennis S. Hudson, III Chairman & Chief Executive Officer Seacoast Banking Corporation of Florida 815 Colorado Avenue Stuart, FL 34994 Re: Seacoast Banking Corporation of Florida Preliminary Proxy Statement on Schedule 14A Filed April 15, 2009 File No. 000-13660 Dear Mr. Hudson: We have limited our review of your filing to those issues we have addressed in our comments. Where indicated, we think you should revise your document in response to these comments. If you disagree, we will consider your explanation as to why our comment is inapplicable or a revision is unnecessary. Please be as detailed as necess ary in your explanation. In some of our comments, we may ask you to pr ovide us with information so we may better understand your disclosure. After reviewing th is 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 requir ements 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 th is letter. Preliminary Proxy Statement on Schedule 14A 1. Please disclose any transactions under consid eration that would involve the issuance of shares of common stock. In addition, describe the intended use of proceeds from any such transaction. 2. Please clarify the table on page 46 to indica te whether it takes into consideration the additional 400,000 shares that would be rese rved for issuance under the Employee Stock Purchase Plan if proposal 5 is approved. Dennis S. Hudson, III Seacoast Banking Corporation of Florida April 17, 2009 Page 2 Closing Comments As appropriate, please amend your filing and respond to these comments. You may wish to provide us with marked copies of the amen dment to expedite our review. Please furnish a cover letter with your amendment that keys your responses to our comments and provides any requested information. Detailed cover letters gr eatly facilitate our review. Please understand that we may have additional comments after reviewing your amendment and responses to our comments. We urge all persons who are responsible for th e accuracy and adequacy of the disclosure in the filing to be certain that the filing includes all information re quired under the Securities Exchange Act of 1934 and that they have provi ded all information investors require for an informed investment decision. Since the compa ny and its management are in possession of all facts relating to a company’s disclosure, they are responsible for the acc uracy and adequacy of the disclosures they have made. In connection with responding to our comment s, 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 sta ff of the Division of Corporati on Finance in our review of your filing or in response to our comments on your filing. Please contact Michael Seaman at (202) 551-3366 or me at (202) 551-3464 with any questions. Sincerely, Kathryn McHale Staff Attorney