SEC Comment Letter for SEACOAST BANKING CORP OF FLORIDA (SBCF) (CIK 0000730708) (SBCF) — Jul 17, 2009
SEACOAST BANKING CORP OF FLORIDA (SBCF) (CIK 0000730708)
Date: July 17, 2009 · CIK: 0000730708 · Accession: 0000000000-09-038215
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 333-160133
Letter
UNITED STATES SECURITIES AND EXCHANGE COMMISSION WASHINGTON, D.C. 20549 DIVISION OF CORPORATION FINANCE Mail Stop 4720 July 17, 2009 By U.S. Mail and Facsimile to: (404) 581-8330; (212) 755-7306 Dennis S. Hudson, III Chief Executive Officer Seacoast Banking Corporation of Florida 815 Colorado Avenue Stuart, Florida 34994 Re: Seacoast Banking Corporation of Florida Registration Statement on Form S-1 Filed June 22, 2009 File No. 333-160133
Dear Mr. Hudson:
We have limited our review of your fili ng to the resolution of the outstanding comments on your Form 10-K for the fiscal year ended December 31, 2008 and related documents. All comments will need to be fu lly resolved before we act on a request for acceleration of the effectiveness of the 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 all in formation required under the Securities Act of 1933 and that they have provided all information investors require for an informed investment decision. 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 the company requests accelerat ion of the effective date of the pending registration statement, it should furnish a letter, at the time of such request, acknowledging that: • should the Commission or the staff, acti ng pursuant to delegated authority, declare the filing effective, it does not foreclose the Commission from taking any action with respect to the filing;
• the action of the Commission or the staff, acting pursuant to delegated authority,
Dennis S. Hudson, III Seacoast Banking Corporation of Florida July 17, 2009 Page 2
in declaring the filing effective, does not relieve the company from its full responsibility for the adequacy and accuracy of the disclosure in the filing; and
• the company may not assert staff comment s and the declaration of effectiveness as a defense in any proceeding initiat ed by the Commission or any person under the federal securities laws of the United States. In addition, please be advi sed that the Division of En forcement has access to all information you provide to the staff of the Di vision of Corporation Finance in connection with your filing. We will consider a written request for acceleration of the effective date of the registration statement as conf irmation of the fact that t hose requesting acceleration are aware of their respective re sponsibilities under the S ecurities Act of 1933 and the Securities Exchange Act of 1934 as they rela te to the proposed public offering of the securities specified in the above registration statement. We will act on the request and, pursuant to delegated authority, grant acce leration of the effective date. We direct your attention to Rules 46 0 and 461 regarding requesting acceleration of a registration statement. Please provide this request at least two business days in advance of the requested effective date. Please contact me at (202) 551-3469 with any questions. S i n c e r e l y ,
Justin Dobbie Attorney Advisor cc: Ralph F. MacDonald III, Esq. John T. Owen, Esq. Jones Day (By facsimile)
Show Raw Text
UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549
DIVISION OF
CORPORATION FINANCE
Mail Stop 4720
July 17, 2009
By U.S. Mail and Facsimile to: (404) 581-8330; (212) 755-7306
Dennis S. Hudson, III Chief Executive Officer Seacoast Banking Corporation of Florida 815 Colorado Avenue Stuart, Florida 34994
Re: Seacoast Banking Corporation of Florida
Registration Statement on Form S-1
Filed June 22, 2009
File No. 333-160133
Dear Mr. Hudson:
We have limited our review of your fili ng to the resolution of the outstanding
comments on your Form 10-K for the fiscal year ended December 31, 2008 and related
documents. All comments will need to be fu lly resolved before we act on a request for
acceleration of the effectiveness of the 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 all in formation required under
the Securities Act of 1933 and that they have provided all information investors require
for an informed investment decision. 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 the company requests accelerat ion of the effective date of the pending
registration statement, it should furnish a letter, at the time of such request,
acknowledging that:
• should the Commission or the staff, acti ng pursuant to delegated authority,
declare the filing effective, it does not foreclose the Commission from taking any
action with respect to the filing;
• the action of the Commission or the staff, acting pursuant to delegated authority,
Dennis S. Hudson, III
Seacoast Banking Corporation of Florida July 17, 2009 Page 2
in declaring the filing effective, does not relieve the company from its full
responsibility for the adequacy and accuracy of the disclosure in the filing; and
• the company may not assert staff comment s and the declaration of effectiveness
as a defense in any proceeding initiat ed by the Commission or any person under
the federal securities laws of the United States.
In addition, please be advi sed that the Division of En forcement has access to all
information you provide to the staff of the Di vision of Corporation Finance in connection
with your filing.
We will consider a written request for acceleration of the effective date of the
registration statement as conf irmation of the fact that t hose requesting acceleration are
aware of their respective re sponsibilities under the S ecurities Act of 1933 and the
Securities Exchange Act of 1934 as they rela te to the proposed public offering of the
securities specified in the above registration statement. We will act on the request and,
pursuant to delegated authority, grant acce leration of the effective date.
We direct your attention to Rules 46 0 and 461 regarding requesting acceleration
of a registration statement. Please provide this request at least two business days in
advance of the requested effective date.
Please contact me at (202) 551-3469 with any questions.
S i n c e r e l y ,
Justin Dobbie
Attorney Advisor
cc: Ralph F. MacDonald III, Esq.
John T. Owen, Esq. Jones Day
(By facsimile)