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
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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.
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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
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Lance O. Diehl
/s/ Virginia D. Kocher
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Virginia D. Kocher
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