SEC Comment Letter for BAR HARBOR BANKSHARES (BHB) (CIK 0000743367) (BHB) — Aug 14, 2014
BAR HARBOR BANKSHARES (BHB) (CIK 0000743367)
Date: Aug. 14, 2014 · CIK: 0000743367 · Accession: 0000000000-14-041247
AI Filing Summary & Sentiment
Letter
August 14, 2014 Via E -mail Mr. Gerald Shencavitz Chief Financial Officer Bar Harbor Bankshares P.O. Box 400 82 Main Street Bar Harbor, ME 04609 -0400
Re: Bar Harbor Bankshares Form 10-K for Fiscal Year Ended December 31, 2013 Filed March 13, 2014 File No. 001 -13349
Dear Mr. Shencavitz :
We have reviewed your filing an d have the following comments. In some of our comments, we may ask you to provide us with information so we may better understand your disclosure.
Please respond to this letter within ten business days by amending your filing, by providing the requested information, or by advising us when you will provide the requested response. If you do not believe our comments apply to your facts and circumstances or do not believe an amendment is appropriate, please tell us why in your response.
After reviewing any amendment to your filing and the information you provide in response to these comments, we may have additional comments.
Item 8. Financial Statements and Supplementary Data , page 11
Reports of Independent Registered Public Accounting Firm , page 11
1. Please tell us which version of the Internal Control – Integrated Fr amework issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO) was used in conducting the audit of the company’s internal controls over financial reporting.
Mr. Gerald Shencavitz Bar Harbor Bankshares August 14, 2014 Page 2
Item 15. Exhibits, Financial Statements Schedules , page 30
Exhibi t 23 - Consent of Independent Registered Public Accounting Firm
2. Please file a new consent of the independent registered public accounting firm to correctly refer to the reports dated March 12, 2014.
We urge all persons who are responsible f or the accuracy and adequacy of the disclosure in the filing to be certain that the filing includes the information the Securities Exchange Act of 1934 and all applicable Exchange Act rules require. Since the company and its management are in possession o f all facts relating to a company’s disclosure, they are responsible for the accuracy and adequacy of the disclosures they have made.
In responding to our comments, please provide a written statement from the company acknowledging 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 the 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.
You may contact Chris Harley at (202) 551 -3695 or me at (202) 551 -3851 if you have questions regarding comments on the financial statements and related matters.
Sincerely,
/s/ Paul Cline
Show Raw Text
August 14, 2014
Via E -mail
Mr. Gerald Shencavitz
Chief Financial Officer
Bar Harbor Bankshares
P.O. Box 400
82 Main Street
Bar Harbor, ME 04609 -0400
Re: Bar Harbor Bankshares
Form 10-K for Fiscal Year Ended December 31, 2013
Filed March 13, 2014
File No. 001 -13349
Dear Mr. Shencavitz :
We have reviewed your filing an d have the following comments. In some of our
comments, we may ask you to provide us with information so we may better understand your
disclosure.
Please respond to this letter within ten business days by amending your filing, by
providing the requested information, or by advising us when you will provide the requested
response. If you do not believe our comments apply to your facts and circumstances or do not
believe an amendment is appropriate, please tell us why in your response.
After reviewing any amendment to your filing and the information you provide in
response to these comments, we may have additional comments.
Item 8. Financial Statements and Supplementary Data , page 11
Reports of Independent Registered Public Accounting Firm , page 11
1. Please tell us which version of the Internal Control – Integrated Fr amework issued
by the Committee of Sponsoring Organizations of the Treadway Commission
(COSO) was used in conducting the audit of the company’s internal controls over
financial reporting.
Mr. Gerald Shencavitz
Bar Harbor Bankshares
August 14, 2014
Page 2
Item 15. Exhibits, Financial Statements Schedules , page 30
Exhibi t 23 - Consent of Independent Registered Public Accounting Firm
2. Please file a new consent of the independent registered public accounting firm to
correctly refer to the reports dated March 12, 2014.
We urge all persons who are responsible f or the accuracy and adequacy of the disclosure
in the filing to be certain that the filing includes the information the Securities Exchange Act of
1934 and all applicable Exchange Act rules require. Since the company and its management are
in possession o f all facts relating to a company’s disclosure, they are responsible for the accuracy
and adequacy of the disclosures they have made.
In responding to our comments, please provide a written statement from the company
acknowledging 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 the 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.
You may contact Chris Harley at (202) 551 -3695 or me at (202) 551 -3851 if you have
questions regarding comments on the financial statements and related matters.
Sincerely,
/s/ Paul Cline
Paul Cline
Staff Accountant