SEC Company Response from SEACOAST BANKING CORP OF FLORIDA (SBCF) (CIK 0000730708) (SBCF) — Sep 27, 2005
SEACOAST BANKING CORP OF FLORIDA (SBCF) (CIK 0000730708)
Date: Sept. 27, 2005 · CIK: 0000730708 · Accession: 0000950144-05-009852
AI Filing Summary & Sentiment
File numbers found in text: 000-13660
Letter
Division of Corporate Finance United States Securities and Exchange Commission Form 10-K for the Fiscal Year Ended December 31, 2004, filed March 17, Form 10-Q for the Fiscal Quarter Ended March 31, 2005 Form 10-Q for the Fiscal Quarter Ended June 30, 2005 File Number 000-13660
Dear Mr. Enunwaonye:
Seacoast Banking Corporation of Florida (“Seacoast” or the “Company”) has filed today with the Securities and Exchange Commission (“Commission”) a Form 10-K/A for the Fiscal Year Ended December 31, 2004 (“10-K/A”) reflecting the comments included in your September 15, 2005 letter. Enclosed for your convenience are (i) two clean copies of the 10-K/A, and (ii) two copies of the 10-K/A that have been marked to show changes from the Form 10-K as filed with the Commission on March 17, 2005.
Set forth below is the Company’s response to the above-referenced comment letter, from the Commission’s staff (the “Staff”) with regard to the Company’s Form 10-K. The Company has provided the following response, which is numbered to correspond to the Staff’s comment. The Company hereby acknowledges that: (i) the Company is responsible for the adequacy and accuracy of the disclosure in the above referenced filings; (ii) Staff comments or changes to disclosure in response to Staff comments do not foreclose the Commission from taking any action with respect to the filings; and (iii) 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.
Bank of America Plaza
101 South Tryon Street, Suite 4000
Charlotte, NC 28280-4000
704-444-1000
Fax: 704-444-1111
90 Park Avenue
New York, NY 10016
22-210-9400
Fax: 212-210-9444
3201 Beechleaf Court, Suite 600
Raleigh, NC 27604-1062
919-862-2200
Fax: 919-862-2260
601 Pennsylvania Avenue, N.W.
North Building, 10th Floor
Washington, DC 20004-2601
Fax: 202-756-333
Mr. Patrick Enunwaonye
September 27, 2005
Page 2
1. Comment.
Section 302 Certifications – Exhibits 31.1 and 31.2
1.
We see that the language in Item 4 to your Section 302 certifications is not exactly as prescribed in the regulation. The required certification must be in the exact form prescribed; and the wording of the required certification may not be changed in any respect. Accordingly, please file an amendment to your Form 10-K that includes the entire filing together with the certifications of each of your current CEO and CFO in the form currently set forth in Item 601(b)(31) of Regulation S-K.
Response.
The Section 302 certification for each of the CEO and CFO have been revised so that they are in exactly the form set forth in Item 601(b)(31) and they are being filed as part of a 10-K/A.
If you have any questions regarding our response to the Staff’s comments, please do not hesitate to call me at the number above.
Sincerely,
/s/ Sherri MacLeay DiMarco
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S.E.C. Comment Letter
Alston&Bird LLP
One Atlantic Center
1201 West Peachtree Street
Atlanta, Georgia 30309-3424
404-881-7000
Fax: 404-881-7777
www.alston. com
Sherri MacLeay DiMarco
Direct Dial: 404-881-7976
E-mail: sdimarco@alston.com
September 27, 2005
Mr. Patrick Enunwaonye
Division of Corporate Finance
United States Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 200549
Re:
Seacoast Banking Corporation of Florida
Form 10-K for the Fiscal Year Ended December 31, 2004, filed March 17,
2005
Form 10-Q for the Fiscal Quarter Ended March 31, 2005
Form 10-Q for the Fiscal Quarter Ended June 30, 2005
File Number 000-13660
Dear Mr. Enunwaonye:
Seacoast Banking Corporation of Florida (“Seacoast” or the “Company”) has
filed today with the Securities and Exchange Commission (“Commission”) a Form 10-K/A for
the Fiscal Year Ended December 31, 2004 (“10-K/A”) reflecting the comments included in your
September 15, 2005 letter. Enclosed for your convenience are (i) two clean copies of the 10-K/A,
and (ii) two copies of the 10-K/A that have been marked to show changes from the Form 10-K as filed
with the Commission on March 17, 2005.
Set forth below is the Company’s response to the above-referenced comment letter, from the
Commission’s staff (the “Staff”) with regard to the Company’s Form 10-K. The Company has
provided the following response, which is numbered to correspond to the Staff’s comment. The
Company hereby acknowledges that: (i) the Company is responsible for the adequacy and accuracy of
the disclosure in the above referenced filings; (ii) Staff comments or changes to disclosure in
response to Staff comments do not foreclose the Commission from taking any action with respect to
the filings; and (iii) 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.
Bank of America Plaza
101 South Tryon Street, Suite 4000
Charlotte, NC 28280-4000
704-444-1000
Fax: 704-444-1111
90 Park Avenue
New York, NY 10016
22-210-9400
Fax: 212-210-9444
3201 Beechleaf Court, Suite 600
Raleigh, NC 27604-1062
919-862-2200
Fax: 919-862-2260
601 Pennsylvania Avenue, N.W.
North Building, 10th Floor
Washington, DC 20004-2601
Fax: 202-756-333
Mr. Patrick Enunwaonye
September 27, 2005
Page 2
1. Comment.
Section 302 Certifications – Exhibits 31.1 and 31.2
1.
We see that the language in Item 4 to your Section 302 certifications is not
exactly as prescribed in the regulation. The required certification must be in the
exact form prescribed; and the wording of the required certification may not be
changed in any respect. Accordingly, please file an amendment to your Form 10-K
that includes the entire filing together with the certifications of each of your
current CEO and CFO in the form currently set forth in Item 601(b)(31) of
Regulation S-K.
Response.
The Section 302 certification for each of the CEO and CFO have been revised so that they are
in exactly the form set forth in Item 601(b)(31) and they are being filed as part of a
10-K/A.
If you have any questions regarding our response to the Staff’s comments, please do not
hesitate to call me at the number above.
Sincerely,
/s/ Sherri MacLeay DiMarco
Sherri MacLeay DiMarco
SMD