SEC Company Response from SEACOAST BANKING CORP OF FLORIDA (SBCF) (CIK 0000730708) (SBCF) — Jan 8, 2013
SEACOAST BANKING CORP OF FLORIDA (SBCF) (CIK 0000730708)
Date: Jan. 8, 2013 · CIK: 0000730708 · Accession: 0001144204-13-001266
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 000-13660
Letter
VIA EDGAR SUBMISSION AND OVERNIGHT DELIVERY Division of Corporate Finance Filed March 26, Form 10-Q for the Quarter Ended June 30, 2012 Filed August 8, File No. 000-13660
Dear Mr. Nolan:
This letter sets forth the responses of Seacoast Banking Corporation of Florida (the “Company”) to the comments received from the staff of the Division of Corporate Finance (the “Staff”) of the Securities and Exchange Commission (the “Commission”) in your letter, dated September 26, 2012. We apologize for the delay in responding to your correspondence, but as you are aware we did not receive a copy of the comment letter until mid-December due to an incorrect email address used by the Staff. The numbered paragraphs below correspond to the numbered paragraphs in your letter. To facilitate your review, we have reproduced below the original text of the Staff’s comments, and have included the Company’s responses immediately following such comments.
Please note that we are filing this response letter via EDGAR submission and are also delivering a copy of the submission to your attention via overnight delivery.
Form 10-K/A for the Fiscal Year Ended December 31, 2011
Item 7. Management’s Discussion and Analysis of Financial Condition and Results of Operations
Allowance and Provision for Loan Losses, page 6
1. We note your disclosure on page 8 that you consider historical losses for the graded loan portfolio based on historical migration of actual losses by grade and a range of losses over various periods. Please tell us and revise future filings to disclose more specifically the historical periods specifically considered in your analysis. In your disclosure, include additional granularity regarding any adjustments made to historical losses and, if applicable, discuss the specific facts and circumstances that is the basis for such adjustments.
RESPONSE: For the graded loans, historical losses are calculated using a loss migration over 4, 8, 12, 16, 20 and 24 quarter intervals. Minimum and maximum average historical loss rates over one to five years are referenced in setting the loss factors by grade within the graded loan portfolio.
Mr. John P. Nolan January 8, 2013 Page 2 of 6
Management uses historical losses as the starting point in its analysis, and qualitative elements are also considered to capture trends within each portion of the graded portfolio. The direction and expectations of past due loans, charge-offs, non-accruals, classified loans, the loan portfolio mix, market conditions, and risk management controls are all considered in setting loss factors for the graded portfolio.
The loan loss migration indicates that the minimum and maximum average loss rates and the median loss rates over the past several quarters have been declining. The level of criticized and classified loans has also declined as a result of a combination of upgrades, loan payoff and loan sales, which have reduced the overall risk profile in the portfolio. Additionally, the risk profile has declined given the dramatic shift in complexion of the portfolio, more specifically, as a result of an overall reduced level of commercial real estate loan concentrations.
The Company will include the additional disclosure requested in the Staff’s comments above in its future filings with the Commission, as applicable.
2. We also note that you consider historical losses over the prior 12 months for non-graded loan portfolios. Please tell us and revise future filings to disclose how you consider historical losses greater than 12 months when determining the general allowance for these loan portfolios. Please be specific, especially in light of the significant charge-offs and provisions for loan losses in prior periods.
RESPONSE: Residential and consumer loans (installment, secured lines, and unsecured lines) are analyzed differently as risk ratings, or grades, are not assigned to individual loans. Residential and consumer loan losses are tracked on a pool basis and monthly histories are averaged for a rolling 12-month historical loss rate. Management believes the recent 12-month loss history is most appropriate as it best represents the allowance for loan losses needed for the current mix of vintages of loans in the portfolio and not the vintages that produced the significant losses in prior years. A prospective loss analysis forecasting credit trends provides opportunity to incorporate views of various loan or property types, loan-to-value ratios, loan concentrations, and economic and environmental factors. Management meets quarterly and, among other matters, discusses local, regional and national foreclosure and economic trends, which supports its judgment related to this prospective analysis. The weighting between the components of historic losses and prospective loss factors are determined by management based on performance expectations.
The Company will include the additional disclosure requested in the Staff’s comments above in its future filings with the Commission, as applicable.
Form 10-Q for the Fiscal Period Ended June 30, 2012
Part I. Financial Information
Item 1. Financial Statements
Notes to Condensed Consolidated Financial Statements (Unaudited)
General
3. Please revise future filings to address the disclosure requirements of ASC 855-10 concerning subsequent events.
Mr. John P. Nolan January 8, 2013 Page 3 of 6
RESPONSE: There were no subsequent events to be disclosed in the Company’s Form 10-Q for the fiscal period ended June 30, 2012 in accordance with the requirements of ASC 855-10. However, to the extent applicable, the Company will disclose such subsequent events in future filings with the Commission.
4. Please consider revising future filings to group footnotes next to each other that include further disclosure for similar financial statements items. For example, please consider grouping footnotes E and J next to each other, which include additional disclosures for loans and impaired loans and the allowance for loan losses.
RESPONSE: The Company will plan to group footnotes that include further disclosure for similar financial statement items next to each other in its future filings, as suggested by the Staff.
Note D – Fair Value Instruments Measured at Fair Value, page 10
5. Please consider revising future filings to separately present, in a tabular format, assets and liabilities measured at fair value using recurring fair value measurements and assets and liabilities measured at fair value using nonrecurring fair value measurements.
RESPONSE: The Company believes the tabular format in Note D with added disclosure for recurring fair value measurements as amended below in footnotes 3 and 4 addresses this comment.
Under ASC 820, fair value measurements for items measured at fair value on a recurring and nonrecurring basis at June 30, 2012 and 2011 included:
(Dollars in thousands)
Fair Value Measurements Quoted
Prices in
Active
Identical
Assets (Level 1) Significant
Other
Observable
Inputs (Level 2) Significant
Unobservable
Inputs (Level 3)
June 30, 2012
Available for sale securities (3) $ 562,691 $ 1,714 $ 560,977 $ 0
Loans available for sale (4) 11,186 11,186
Loans (1) 34,468 12,802 21,666
Other real estate owned (2) 7,219 1,783 5,436
June 30, 2011
Available for sale securities (3) $ 611,231 $ 4,224 $ 607,007 $ 0
Loans available for sale (4) 4,758 4,758
Loans (1) 32,124 10,873 21,251
Other real estate owned (2) 25,877 2,553 23,324
____________
(1) See Note E. Nonrecurring fair value adjustments to loans identified as impaired reflect full or partial write-downs that are based on the loan’s observable market price or current appraised value of the collateral in accordance with ASC 310.
(2) Fair value is measured on a nonrecurring basis in accordance with ASC 360.
(3) See Note H for further detail of recurring fair value basis of individual investment categories.
(4) Recurring fair value basis determined using observable market data.
The Company will include the applicable information in the table above as requested in the Staff’s comments above in its future filings with the Commission.
Mr. John P. Nolan January 8, 2013 Page 4 of 6
6. Please tell us and revise future filings to disclose a description of the valuation technique(s) and the inputs used in the fair value measurement for recurring and nonrecurring fair value measurements categorized within Level 2 and Level 3 of the fair value hierarchy in accordance with ASC 820-10-50-2-bbb.
RESPONSE: The fair value of impaired loans, which are not troubled debt restructurings (TDRs), is based on recent real estate appraisals less estimated costs of sale. For residential real estate impaired loans, appraised values or internal evaluation are based on the comparative sales approach. These impaired loans are considered a Level 2 in the fair value hierarchy. For commercial and commercial real estate impaired loan, evaluators may use either a single valuation approach or a combination of approaches, such as comparative sales, cost and/or income approach. A significant unobservable input in the income approach is the estimated capitalization rate for a given piece of collateral. At June 30, 2012, the range of capitalization rates utilized to determine fair value of the underlying collateral ranged from 8% to 9%. Adjustments to comparable sales may be made by an appraiser to reflect local market conditions or other economic factors and may result in changes in the fair value of a given asset over time. As such, the fair value of these impaired loans is considered a Level 3 in the fair value hierarchy.
Fair value of available for sale securities are determined using valuation techniques for individual investments as disclosed in Note H.
The Company will include the additional disclosure requested in the Staff’s comments above in its future filings with the Commission, as applicable.
7. Please revise future filings to include the disclosure requirements of ASC 820-10-50-2E for each class of assets and liabilities not measured at fair value in the statement of financial position but for which the fair value is disclosed.
RESPONSE: The carrying value amount and fair values for other financial instruments that are not measured at fair value on a recurring basis in the balance sheet at June 30, 2012 are as follows:
June 30, 2012
Carrying Fair Value Level
(Dollars in thousands) Amount Level 1 Level 2 Level 3 Total
Assets:
Securities held to maturity $ 17,122 $ 0 $ 17,799 $ 0 $ 17,799
Loans, net 1,196,719 1,204,843 21,666 1,226,509
Loans held for sale 11,186 11,186 11,186
Liabilities:
Deposits 1,689,584 1,691,984 1,691,984
Borrowings 189,489 195,123 195,123
Long-term debt 53,610 32,166 32,166
The Company will include the additional disclosure requested in the Staff’s comments above in its future filings with the Commission, as applicable.
Item 2. Management’s Discussion and Analysis of Financial Condition and Results of Operations
Allowance for Loan Losses, page 47
Mr. John P. Nolan January 8, 2013 Page 5 of 6
8. We note your disclosure on pages 47-51 discussing the trends in the loan portfolio and allowance for loan losses during 2012. Please tell us in detail and revise future filings to more comprehensively bridge the gap between the changes in the credit quality of your loan portfolio and the amount of your provision for loan loss recorded during the period and the amount of the allowance for loan losses at period end. Your analysis should quantify each component of your allowance for loan losses (ASC 310-10, 450-20) and the applicable loan portfolio for each component and should explain how you determined that each component was directionally consistent with the underlying credit quality of the applicable loan portfolio. Please be as specific and detailed as necessary to provide an investor with a clear understanding of the observed changes in credit quality in each applicable loan portfolio and how these changes, as well as any other key drivers, impacted each component of the allowance for loan losses.
RESPONSE: The reduced level of impaired loans and lower classified loans (special mention and substandard grades) contributed to a lower risk of loss and the lower allowance for loan losses as of June 30, 2012 compared to a year ago. The risk profile for the loan portfolio has been reduced by strengthening credit management methodologies and implementing a low-risk “back-to-basics” strategic plan for loan growth.
New loan production has shifted to adjustable rate residential real estate loans, owner-occupied commercial real estate and small business loans for professionals and businesses, and consumer lending. Strategies, processes and controls are in place to ensure that new loan production is well underwritten and maintains a focus on smaller, more diversified and lower-risk lending.
Aided by initiatives embodied in new loan programs and continued aggressive collection actions, the portfolio mix has changed dramatically and has become more diversified. The improved mix is most evident by the significant reductions in the income producing commercial real estate and construction and land development portfolios over the last several years, as demonstrated by the following table:
(Dollars in thousands) 6/30/2010 6/30/2011 6/30/2012
Special Mention Loans 53,126 65,633 40,990
Substandard Loans 6,306 6,254 22,993
Total Criticized & Classified Loans 59,432 71,887 63,983
Special Mention Loans 20.13 % 26.90 % 17.60 %
Substandard Loans 2.39 % 2.56 % 9.88 %
Total Crit. & Classified Loans % Tier 1 & ALLL 22.52 % 29.46 % 27.48 %
Total Impaired Loans 157,361 106,403 103,324
Total Non-Performing Assets 109,903 72,042 55,701
Total Loans + OREO 1,319,618 1,214,822 1,228,573
NPA % 8.33 % 5.93 % 4.53 %
Mr. John P. Nolan January 8, 2013 Page 6 of 6
The Company will include the additional disclosure requested in the Staff’s comments above in its future filings with the Commission, as applicable.
In connection with these responses to the Staff’s comment letter, the Company acknowledges 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 any 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.
We appreciate your consideration of this matter. If you have any additional questions please do not hesitate to contact me at 772-221-2825.
Sincerely,
/s/ William R. Hahl
Show Raw Text
CORRESP
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filename1.htm
January 8, 2013
VIA EDGAR SUBMISSION AND OVERNIGHT DELIVERY
Mr. John P. Nolan
Senior Assistant Chief Accountant
Division of Corporate Finance
U.S. Securities and Exchange Commission
100 F Street, NE
Washington D.C. 20549
Re: Seacoast Banking Corporation of Florida
Form 10-K/A for
the Year Ended December 31, 2011
Filed March 26,
2012
Form 10-Q for the
Quarter Ended June 30, 2012
Filed August 8,
2012
File No. 000-13660
Dear Mr. Nolan:
This letter sets forth
the responses of Seacoast Banking Corporation of Florida (the “Company”) to the comments received from the staff of
the Division of Corporate Finance (the “Staff”) of the Securities and Exchange Commission (the “Commission”)
in your letter, dated September 26, 2012. We apologize for the delay in responding to your correspondence,
but as you are aware we did not receive a copy of the comment letter until mid-December due to an incorrect email address used
by the Staff. The numbered paragraphs below correspond to the numbered paragraphs in your letter. To facilitate your review, we
have reproduced below the original text of the Staff’s comments, and have included the Company’s responses immediately
following such comments.
Please note that we
are filing this response letter via EDGAR submission and are also delivering a copy of the submission to your attention via overnight
delivery.
Form 10-K/A for the Fiscal Year Ended
December 31, 2011
Item 7. Management’s Discussion
and Analysis of Financial Condition and Results of Operations
Allowance and Provision for Loan Losses,
page 6
1. We note your disclosure on page 8 that you consider historical losses for the graded loan portfolio
based on historical migration of actual losses by grade and a range of losses over various periods. Please tell us and revise future
filings to disclose more specifically the historical periods specifically considered in your analysis. In your disclosure, include
additional granularity regarding any adjustments made to historical losses and, if applicable, discuss the specific facts and circumstances
that is the basis for such adjustments.
RESPONSE: For
the graded loans, historical losses are calculated using a loss migration over 4, 8, 12, 16, 20 and 24 quarter intervals. Minimum
and maximum average historical loss rates over one to five years are referenced in setting the loss factors by grade within the
graded loan portfolio.
Mr. John P. Nolan
January 8, 2013
Page 2 of 6
Management uses historical
losses as the starting point in its analysis, and qualitative elements are also considered to capture trends within each portion
of the graded portfolio. The direction and expectations of past due loans, charge-offs, non-accruals, classified loans, the loan
portfolio mix, market conditions, and risk management controls are all considered in setting loss factors for the graded portfolio.
The loan loss migration
indicates that the minimum and maximum average loss rates and the median loss rates over the past several quarters have been declining.
The level of criticized and classified loans has also declined as a result of a combination of upgrades, loan payoff and loan sales,
which have reduced the overall risk profile in the portfolio. Additionally, the risk profile has declined given the dramatic
shift in complexion of the portfolio, more specifically, as a result of an overall reduced level of commercial real estate loan
concentrations.
The Company will include
the additional disclosure requested in the Staff’s comments above in its future filings with the Commission, as applicable.
2. We also note that you consider historical losses over the prior 12 months for non-graded loan
portfolios. Please tell us and revise future filings to disclose how you consider historical losses greater than 12 months when
determining the general allowance for these loan portfolios. Please be specific, especially in light of the significant charge-offs
and provisions for loan losses in prior periods.
RESPONSE: Residential
and consumer loans (installment, secured lines, and unsecured lines) are analyzed differently as risk ratings, or grades, are not
assigned to individual loans. Residential and consumer loan losses are tracked on a pool basis and monthly histories are averaged
for a rolling 12-month historical loss rate. Management believes the recent 12-month loss history is most appropriate as it best
represents the allowance for loan losses needed for the current mix of vintages of loans in the portfolio and not the vintages
that produced the significant losses in prior years. A prospective loss analysis forecasting credit trends provides opportunity
to incorporate views of various loan or property types, loan-to-value ratios, loan concentrations, and economic and environmental
factors. Management meets quarterly and, among other matters, discusses local, regional and national foreclosure and economic trends,
which supports its judgment related to this prospective analysis. The weighting between the components of historic losses and prospective
loss factors are determined by management based on performance expectations.
The Company will include
the additional disclosure requested in the Staff’s comments above in its future filings with the Commission, as applicable.
Form 10-Q for the Fiscal Period Ended
June 30, 2012
Part I. Financial Information
Item 1. Financial Statements
Notes to Condensed Consolidated Financial
Statements (Unaudited)
General
3. Please revise future filings to address the disclosure requirements of ASC 855-10 concerning
subsequent events.
Mr. John P. Nolan
January 8, 2013
Page 3 of 6
RESPONSE: There
were no subsequent events to be disclosed in the Company’s Form 10-Q for the fiscal period ended June 30, 2012 in accordance
with the requirements of ASC 855-10. However, to the extent applicable, the Company will disclose such subsequent events in future
filings with the Commission.
4. Please consider revising future filings to group footnotes next to each other that include further
disclosure for similar financial statements items. For example, please consider grouping footnotes E and J next to each other,
which include additional disclosures for loans and impaired loans and the allowance for loan losses.
RESPONSE: The
Company will plan to group footnotes that include further disclosure for similar financial statement items next to each other in
its future filings, as suggested by the Staff.
Note D – Fair Value Instruments
Measured at Fair Value, page 10
5. Please consider revising future filings to separately present, in a tabular format, assets and
liabilities measured at fair value using recurring fair value measurements and assets and liabilities measured at fair value using
nonrecurring fair value measurements.
RESPONSE: The
Company believes the tabular format in Note D with added disclosure for recurring fair value measurements as amended below in footnotes
3 and 4 addresses this comment.
Under ASC 820, fair
value measurements for items measured at fair value on a recurring and nonrecurring basis at June 30, 2012 and 2011 included:
(Dollars in thousands)
Fair Value
Measurements
Quoted
Prices in
Active
Identical
Assets
(Level 1)
Significant
Other
Observable
Inputs
(Level 2)
Significant
Unobservable
Inputs
(Level 3)
June 30, 2012
Available for sale securities (3)
$ 562,691
$ 1,714
$ 560,977
$ 0
Loans available for sale (4)
11,186
0
11,186
0
Loans (1)
34,468
0
12,802
21,666
Other real estate owned (2)
7,219
0
1,783
5,436
June 30, 2011
Available for sale securities (3)
$ 611,231
$ 4,224
$ 607,007
$ 0
Loans available for sale (4)
4,758
0
4,758
0
Loans (1)
32,124
0
10,873
21,251
Other real estate owned (2)
25,877
0
2,553
23,324
____________
(1) See Note E. Nonrecurring fair value adjustments to
loans identified as impaired reflect full or partial write-downs that are based on the loan’s observable market price or
current appraised value of the collateral in accordance with ASC 310.
(2) Fair value is measured on a nonrecurring basis in
accordance with ASC 360.
(3) See Note H for further detail of recurring fair value
basis of individual investment categories.
(4) Recurring fair value basis determined using observable
market data.
The Company will include
the applicable information in the table above as requested in the Staff’s comments above in its future filings with the Commission.
Mr. John P. Nolan
January 8, 2013
Page 4 of 6
6. Please tell us and revise future filings to disclose a description of the valuation technique(s)
and the inputs used in the fair value measurement for recurring and nonrecurring fair value measurements categorized within Level
2 and Level 3 of the fair value hierarchy in accordance with ASC 820-10-50-2-bbb.
RESPONSE: The
fair value of impaired loans, which are not troubled debt restructurings (TDRs), is based on recent real estate appraisals less
estimated costs of sale. For residential real estate impaired loans, appraised values or internal evaluation are based on the comparative
sales approach. These impaired loans are considered a Level 2 in the fair value hierarchy. For commercial and commercial real estate
impaired loan, evaluators may use either a single valuation approach or a combination of approaches, such as comparative sales,
cost and/or income approach. A significant unobservable input in the income approach is the estimated capitalization rate for a
given piece of collateral. At June 30, 2012, the range of capitalization rates utilized to determine fair value of the underlying
collateral ranged from 8% to 9%. Adjustments to comparable sales may be made by an appraiser to reflect local market conditions
or other economic factors and may result in changes in the fair value of a given asset over time. As such, the fair value of these
impaired loans is considered a Level 3 in the fair value hierarchy.
Fair value of available
for sale securities are determined using valuation techniques for individual investments as disclosed in Note H.
The Company will include
the additional disclosure requested in the Staff’s comments above in its future filings with the Commission, as applicable.
7. Please revise future filings to include the disclosure requirements of ASC 820-10-50-2E for
each class of assets and liabilities not measured at fair value in the statement of financial position but for which the fair value
is disclosed.
RESPONSE: The
carrying value amount and fair values for other financial instruments that are not measured at fair value on a recurring basis
in the balance sheet at June 30, 2012 are as follows:
June 30, 2012
Carrying
Fair Value Level
(Dollars in thousands)
Amount
Level 1
Level 2
Level 3
Total
Assets:
Securities held to maturity
$ 17,122
$ 0
$ 17,799
$ 0
$ 17,799
Loans, net
1,196,719
0
1,204,843
21,666
1,226,509
Loans held for sale
11,186
0
11,186
0
11,186
Liabilities:
Deposits
1,689,584
0
1,691,984
0
1,691,984
Borrowings
189,489
0
195,123
0
195,123
Long-term debt
53,610
0
0
32,166
32,166
The Company will include the additional
disclosure requested in the Staff’s comments above in its future filings with the Commission, as applicable.
Item 2. Management’s Discussion
and Analysis of Financial Condition and Results of Operations
Allowance for Loan Losses, page 47
Mr. John P. Nolan
January 8, 2013
Page 5 of 6
8. We note your disclosure on pages 47-51 discussing the trends in the loan portfolio and allowance
for loan losses during 2012. Please tell us in detail and revise future filings to more comprehensively bridge the gap between
the changes in the credit quality of your loan portfolio and the amount of your provision for loan loss recorded during the period
and the amount of the allowance for loan losses at period end. Your analysis should quantify each component of your allowance for
loan losses (ASC 310-10, 450-20) and the applicable loan portfolio for each component and should explain how you determined that
each component was directionally consistent with the underlying credit quality of the applicable loan portfolio. Please be as specific
and detailed as necessary to provide an investor with a clear understanding of the observed changes in credit quality in each applicable
loan portfolio and how these changes, as well as any other key drivers, impacted each component of the allowance for loan losses.
RESPONSE: The
reduced level of impaired loans and lower classified loans (special mention and substandard grades) contributed to a lower risk
of loss and the lower allowance for loan losses as of June 30, 2012 compared to a year ago. The risk profile for the loan portfolio
has been reduced by strengthening credit management methodologies and implementing a low-risk “back-to-basics” strategic
plan for loan growth.
New loan production has shifted to adjustable
rate residential real estate loans, owner-occupied commercial real estate and small business loans for professionals and businesses,
and consumer lending. Strategies, processes and controls are in place to ensure that new loan production is well underwritten and
maintains a focus on smaller, more diversified and lower-risk lending.
Aided by initiatives embodied in new loan
programs and continued aggressive collection actions, the portfolio mix has changed dramatically and has become more diversified.
The improved mix is most evident by the significant reductions in the income producing commercial real estate and construction
and land development portfolios over the last several years, as demonstrated by the following table:
(Dollars in thousands)
6/30/2010
6/30/2011
6/30/2012
Special Mention Loans
53,126
65,633
40,990
Substandard Loans
6,306
6,254
22,993
Total Criticized & Classified Loans
59,432
71,887
63,983
Special Mention Loans
20.13 %
26.90 %
17.60 %
Substandard Loans
2.39 %
2.56 %
9.88 %
Total Crit. & Classified Loans % Tier 1 & ALLL
22.52 %
29.46 %
27.48 %
Total Impaired Loans
157,361
106,403
103,324
Total Non-Performing Assets
109,903
72,042
55,701
Total Loans + OREO
1,319,618
1,214,822
1,228,573
NPA %
8.33 %
5.93 %
4.53 %
Mr. John P. Nolan
January 8, 2013
Page 6 of 6
The Company will include the additional
disclosure requested in the Staff’s comments above in its future filings with the Commission, as applicable.
In connection with these responses to the Staff’s comment
letter, the Company acknowledges 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 any 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.
We appreciate your consideration of this
matter. If you have any additional questions please do not hesitate to contact me at 772-221-2825.
Sincerely,
/s/ William R. Hahl
William R. Hahl
Executive Vice President and Chief Financial
Officer
Seacoast Banking Corporation of Florida