SEC Comment Letter 0000000000-24-010571 to CITIZENS FINANCIAL SERVICES INC (CZFS) (CIK 0000739421) (CZFS)
CITIZENS FINANCIAL SERVICES INC (CZFS) (CIK 0000739421)
Date: Sept. 18, 2024 · CIK: 0000739421 · Accession: 0000000000-24-010571
AI Filing Summary & Sentiment
File numbers found in text: 001-41410
Letter
September 18, 2024 Stephen J. Guillaume Chief Financial Officer Citizens Financial Services, Inc. 15 South Main Street Mansfield, Pennsylvania 16933 Re:Citizens Financial Services, Inc. Form 10-K for the Fiscal Year Ended December 31, 2023 File No. 001-41410 Dear Stephen J. Guillaume: We have limited our review of your filing to the financial statements and related disclosures and have the following comment. Please respond to this letter within ten business days by providing the requested information or advise us as soon as possible when you will respond. If you do not believe a comment applies to your facts and circumstances, please tell us why in your response. After reviewing your response to this letter, we may have additional comments. Form 10-K filed March 7, 2024 Management's Discussion and Analysis of Financial Condition and Results of Operations Loans, page 34 1.We note the tabular disclosure on page 34 detailing the composition of your gross loan portfolio, which includes commercial real estate (“CRE”). Given the significance of CRE in your total loan portfolio, please revise your disclosures, in future filings, to further disaggregate the composition of your CRE loan portfolio by separately presenting the components of the portfolio by key borrower type (e.g., by office, hotel, multifamily, etc.) as well as whether the loans are owner occupied or not. Also, to the extent that there are material characteristics (e.g., current weighted average and/or range of loan-to-value ratios, occupancy rates, etc.) material to an investor’s understanding of your CRE loan portfolio, include those details in future filings. Finally, revise to describe the specific details of any risk management policies, procedures or other actions undertaken by management in response to the current environment. In closing, we remind you that the company and its management are responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or
September 18, 2024 Page 2 absence of action by the staff. Please contact Sarmad Makhdoom at 202-551-5776 or Marc Thomas at 202-551-3452 with any questions. Sincerely, Division of Corporation Finance Office of Finance
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September 18, 2024
Stephen J. Guillaume
Chief Financial Officer
Citizens Financial Services, Inc.
15 South Main Street
Mansfield, Pennsylvania 16933
Re:Citizens Financial Services, Inc.
Form 10-K for the Fiscal Year Ended December 31, 2023
File No. 001-41410
Dear Stephen J. Guillaume:
We have limited our review of your filing to the financial statements and related
disclosures and have the following comment.
Please respond to this letter within ten business days by providing the requested
information or advise us as soon as possible when you will respond. If you do not believe a
comment applies to your facts and circumstances, please tell us why in your response.
After reviewing your response to this letter, we may have additional comments.
Form 10-K filed March 7, 2024
Management's Discussion and Analysis of Financial Condition and Results of Operations
Loans, page 34
1.We note the tabular disclosure on page 34 detailing the composition of your gross loan
portfolio, which includes commercial real estate (“CRE”). Given the significance of CRE
in your total loan portfolio, please revise your disclosures, in future filings, to further
disaggregate the composition of your CRE loan portfolio by separately presenting the
components of the portfolio by key borrower type (e.g., by office, hotel, multifamily, etc.)
as well as whether the loans are owner occupied or not. Also, to the extent that there are
material characteristics (e.g., current weighted average and/or range of loan-to-value
ratios, occupancy rates, etc.) material to an investor’s understanding of your CRE loan
portfolio, include those details in future filings. Finally, revise to describe the specific
details of any risk management policies, procedures or other actions undertaken by
management in response to the current environment.
In closing, we remind you that the company and its management are responsible for the
accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or
September 18, 2024
Page 2
absence of action by the staff.
Please contact Sarmad Makhdoom at 202-551-5776 or Marc Thomas at 202-551-3452
with any questions.
Sincerely,
Division of Corporation Finance
Office of Finance