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SEC Company Response from CCFNB BANCORP INC (CCFN) (CIK 0000731122) (CCFN) — Aug 8, 2005

CCFNB BANCORP INC (CCFN) (CIK 0000731122)
Date: Aug. 8, 2005 · CIK: 0000731122 · Accession: 0000893220-05-001870

AI Filing Summary & Sentiment

Date
August 8, 2005
Author
Not clearly detected
Form
CORRESP
Company
CCFNB BANCORP INC (CCFN) (CIK 0000731122)

Letter

232 EAST STREET BLOOMSBURG, PA 17815 570 784-4400 August 8, 2005 John P. Nolan, Accounting Branch Chief Lisa Haynes, Staff Accountant Division of Corporate Finance Securities and Exchange Commission Mail Stop 4561 Washington, DC 20549

RE: CCFNB BANCORP, INC. - FORM 10-K FOR THE FISCAL YEAR ENDED DECEMBER 31, 2004 - FORM 10-Q FOR THE QUARTER ENDED MARCH 31, 2005 - FILE NO. 0-19028

Dear Mr. Nolan and Ms. Haynes:

We are filing herewith an amendment to each of our reports described above, and to address your comments delineated below, we respond in bold as follows:

1. We note your disclosure that you evaluated the effectiveness of your disclosure controls and procedures and internal controls and procedures for financial reporting within 90 days prior to the date of your Form 10-K. Please revise to clarify that your evaluation of the effectiveness of your disclosure controls and procedures was as of the end of the fiscal year. If your evaluation was as of a date other than the end of the fiscal year, please tell us how you believe you have complied with Section II.F.1 and 3 of the SEC's Final Rule on Management's Reports on Internal Control Over Financial Reporting and Certification of Disclosure in Exchange Act Periodic Reports (Release Nos. 33-8238 and 34-47986).

WE HAVE AMENDED ITEM 9A TO CLARIFY THAT OUR EVALUATION OF THE EFFECTIVENESS OF OUR DISCLOSURE CONTROLS AND PROCEDURES WAS AS OF DECEMBER 31, 2004.

2. We note that your discussion of controls and procedures is identical to the discussion you included in your Form 10-K. Please revise to include the disclosures required by Item 307 of Regulation S-K as of the end of the quarter.

WE HAVE REVISED OUR DISCLOSURE UNDER PART 1 - FINANCIAL INFORMATION - CONTROLS AND PROCEDURES TO INCLUDE THE DISCLOSURE REQUIRED BY ITEM 307 OF REGULATION S-K TO STATE THAT OUR CONCLUSIONS, REGARDING THE EFFECTIVENESS OF OUR DISCLOSURE CONTROLS AND PROCEDURES, IS AS OF MARCH 31, 2005.

<PAGE>

August 8, 2005 Page 2

3. To the extent you revise your Form 10-K and 10-Q as a result of the above comments, please also revise your management certifications pursuant to the Sarbanes-Oxley Act of 2002.

WE HAVE REVISED OUR MANAGEMENT CERTIFICATIONS FOR BOTH OF THESE REPORTS TO REFLECT THE REVISIONS THAT WE MADE.

We hereby acknowledge that:

- CCFNB Bancorp, Inc. is responsible for the adequacy and accuracy of the disclosure in the filings;

- Staff comments or changes to disclosure in response to staff comments in the filings reviewed by the staff do not foreclose the Commission from taking any action with respect to the filing; and

- CCFNB Bancorp, Inc. 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.

If staff has any further comments concerning these reports, please contact Lance O. Diehl, President and CEO, at (570) 387 3464 or Virginia D. Kocher, Treasurer at (570) 387-4016.

/s/ Lance O. Diehl ------------------------------ Lance O. Diehl

/s/ Virginia D. Kocher ------------------------------ Virginia D. Kocher

Show Raw Text
<DOCUMENT>
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<TEXT>
<PAGE>

                              CCFNB BANCORP, INC.

                                232 EAST STREET
                              BLOOMSBURG, PA 17815
                                  570 784-4400

                                                                  August 8, 2005

John P. Nolan, Accounting Branch Chief
Lisa Haynes, Staff Accountant
Division of Corporate Finance
Securities and Exchange Commission
Mail Stop 4561
Washington, DC  20549

      RE:   CCFNB BANCORP, INC.
            - FORM 10-K FOR THE FISCAL YEAR ENDED DECEMBER 31, 2004
            - FORM 10-Q FOR THE QUARTER ENDED MARCH 31, 2005
            - FILE NO. 0-19028

Dear Mr. Nolan and Ms. Haynes:

      We are filing herewith an amendment to each of our reports described
above, and to address your comments delineated below, we respond in bold as
follows:

      1. We note your disclosure that you evaluated the effectiveness of your
disclosure controls and procedures and internal controls and procedures for
financial reporting within 90 days prior to the date of your Form 10-K. Please
revise to clarify that your evaluation of the effectiveness of your disclosure
controls and procedures was as of the end of the fiscal year. If your evaluation
was as of a date other than the end of the fiscal year, please tell us how you
believe you have complied with Section II.F.1 and 3 of the SEC's Final Rule on
Management's Reports on Internal Control Over Financial Reporting and
Certification of Disclosure in Exchange Act Periodic Reports (Release Nos.
33-8238 and 34-47986).

      WE HAVE AMENDED ITEM 9A TO CLARIFY THAT OUR EVALUATION OF THE
EFFECTIVENESS OF OUR DISCLOSURE CONTROLS AND PROCEDURES WAS AS OF DECEMBER 31,
2004.

      2. We note that your discussion of controls and procedures is identical to
the discussion you included in your Form 10-K. Please revise to include the
disclosures required by Item 307 of Regulation S-K as of the end of the quarter.

      WE HAVE REVISED OUR DISCLOSURE UNDER PART 1 - FINANCIAL INFORMATION -
CONTROLS AND PROCEDURES TO INCLUDE THE DISCLOSURE REQUIRED BY ITEM 307 OF
REGULATION S-K TO STATE THAT OUR CONCLUSIONS, REGARDING THE EFFECTIVENESS OF OUR
DISCLOSURE CONTROLS AND PROCEDURES, IS AS OF MARCH 31, 2005.

<PAGE>

August 8, 2005
Page 2

      3. To the extent you revise your Form 10-K and 10-Q as a result of the
above comments, please also revise your management certifications pursuant to
the Sarbanes-Oxley Act of 2002.

      WE HAVE REVISED OUR MANAGEMENT CERTIFICATIONS FOR BOTH OF THESE REPORTS TO
REFLECT THE REVISIONS THAT WE MADE.

      We hereby acknowledge that:

      -     CCFNB Bancorp, Inc. is responsible for the adequacy and accuracy of
            the disclosure in the filings;

      -     Staff comments or changes to disclosure in response to staff
            comments in the filings reviewed by the staff do not foreclose the
            Commission from taking any action with respect to the filing; and

      -     CCFNB Bancorp, Inc. 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.

      If staff has any further comments concerning these reports, please contact
Lance O. Diehl, President and CEO, at (570) 387 3464 or Virginia D. Kocher,
Treasurer at (570) 387-4016.

                                                 /s/ Lance O. Diehl
                                                 ------------------------------
                                                 Lance O. Diehl

                                                 /s/ Virginia D. Kocher
                                                 ------------------------------
                                                 Virginia D. Kocher
</TEXT>
</DOCUMENT>