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SEC Company Response from CCFNB BANCORP INC (CCFN) (CIK 0000731122) (CCFN) — Aug 15, 2005

CCFNB BANCORP INC (CCFN) (CIK 0000731122)
Date: Aug. 15, 2005 · CIK: 0000731122 · Accession: 0000893220-05-001981

AI Filing Summary & Sentiment

Date
August 12, 2005
Author
Not clearly detected
Form
CORRESP
Company
CCFNB BANCORP INC (CCFN) (CIK 0000731122)

Letter

<PAGE> CCFNB BANCORP, INC. 232 EAST STREET BLOOMSBURG, PA 17815 570 784 4400 August 12, 2005 Donald Walker, Senior Assistant Chief Accountant Lisa Haynes, Staff Accountant Division of Corporate Finance Securities and Exchange Commission Mail Stop 4561 Washington, DC 20549

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

Dear Mr. Walker and Ms. Haynes:

We are filing herewith a second amendment to our 10Q described above, and to address your comments delineated below, we respond in bold as follows:

1. Please revise your amended disclosures to more clearly differentiate between internal controls over financial reporting and disclosure controls and procedures, as defined in Rule 13a-15(e) and (f) of Regulation S-X. Specifically, please revise to disclose:

- Conclusions of your principal executive and financial officers regarding the effectiveness of your disclosure controls and procedures, and

- Any changes in your internal control over financial reporting during the quarter that has materially affected or is reasonably likely to affect your internal control over financial reporting.

WE HAVE REVISED OUR DISCLOSURE UNDER PART 1 - FINANCIAL INFORMATION - CONTROLS AND PROCEDURES TO MORE CLEARLY DIFFERENTIATE BETWEEN INTERNAL CONTROLS OVER FINANCIAL REPORTING AND DISCLOSURE CONTROLS AND PROCEDURES.

WE HAVE SPECIFICALLY DISCUSSED CONCLUSIONS OF OUR PRINCIPAL EXECUTIVE AND FINANCIAL OFFICERS REGARDING THE EFFECTIVENESS OF OUR DISCLOSURE CONTROLS AND PROCEDURES AND

WE HAVE SPECIFICALLY DISCLOSED ANY CHANGES IN OUR INTERNAL CONTROL OVER FINANCIAL REPORTING DURING THE QUARTER THAT HAS MATERIALLY AFFECTED OR IS REASONABLY LIKELY TO AFFECT OUR INTERNAL CONTROL OVER FINANCIAL REPORTING. <PAGE> August 8, 2005

Page 2

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>
<TYPE>CORRESP
<SEQUENCE>1
<FILENAME>filename1.txt
<TEXT>
<PAGE>
                               CCFNB BANCORP, INC.
                                 232 EAST STREET
                              BLOOMSBURG, PA 17815
                                  570 784 4400

                                                                 August 12, 2005

Donald Walker, Senior Assistant Chief Accountant
Lisa Haynes, Staff Accountant
Division of Corporate Finance
Securities and Exchange Commission
Mail Stop 4561
Washington, DC 20549

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

Dear Mr. Walker and Ms. Haynes:

     We are filing herewith a second amendment to our 10Q described above, and
to address your comments delineated below, we respond in bold as follows:

     1. Please revise your amended disclosures to more clearly differentiate
between internal controls over financial reporting and disclosure controls and
procedures, as defined in Rule 13a-15(e) and (f) of Regulation S-X.
Specifically, please revise to disclose:

     -    Conclusions of your principal executive and financial officers
          regarding the effectiveness of your disclosure controls and
          procedures, and

     -    Any changes in your internal control over financial reporting during
          the quarter that has materially affected or is reasonably likely to
          affect your internal control over financial reporting.

     WE HAVE REVISED OUR DISCLOSURE UNDER PART 1 - FINANCIAL INFORMATION -
     CONTROLS AND PROCEDURES TO MORE CLEARLY DIFFERENTIATE BETWEEN INTERNAL
     CONTROLS OVER FINANCIAL REPORTING AND DISCLOSURE CONTROLS AND PROCEDURES.

     WE HAVE SPECIFICALLY DISCUSSED CONCLUSIONS OF OUR PRINCIPAL EXECUTIVE AND
     FINANCIAL OFFICERS REGARDING THE EFFECTIVENESS OF OUR DISCLOSURE CONTROLS
     AND PROCEDURES AND

     WE HAVE SPECIFICALLY DISCLOSED ANY CHANGES IN OUR INTERNAL CONTROL OVER
     FINANCIAL REPORTING DURING THE QUARTER THAT HAS MATERIALLY AFFECTED OR IS
     REASONABLY LIKELY TO AFFECT OUR INTERNAL CONTROL OVER FINANCIAL REPORTING.
<PAGE>
August 8, 2005

Page 2

     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>