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SEC Company Response from AUBURN NATIONAL BANCORPORATION INC (AUBN) (CIK 0000750574) (AUBN) — Jun 15, 2005

AUBURN NATIONAL BANCORPORATION INC (AUBN) (CIK 0000750574)
Date: June 15, 2005 · CIK: 0000750574 · Accession: 0001193125-05-125825

AI Filing Summary & Sentiment

Referenced dates: May 25, 2005

Date
March 31, 2005
Author
/s/ C. Wayne Alderman
Form
CORRESP
Company
AUBURN NATIONAL BANCORPORATION INC (AUBN) (CIK 0000750574)

Letter

United States Securities and Exchange Commission Division of Corporation Finance Washington DC 20002 Re: Auburn National Bancorporation, Inc. Form 10-K filed March 31, 2005 File No. 0-26486

Dear Messrs. Nolan and Adames,

Auburn National Bancorporation, Inc. (the “Company”) received your letter dated May 25, 2005 regarding the Securities and Exchange Commissions Staff’s comments on the above-referenced filing. The Company’s response to the Staff’s comments follows.

Form 10-K for Year ended December 31, 2004

Note (1)(e). Summary of Significant Accounting Policies – Loans – page 52

1. Comment. We refer to the statement that interest on loans is credited to income using the simple interest method. In this regard, explain to us the basis for using this method to record interest instead of the effective interest method prescribed by paragraph 19 of SFAS 91 computed by calculating a constant effective yield.

Response. The Company has determined that its statement regarding the use of the simple interest method did not accurately reflect the method actually used. The Company follows SFAS 91 and records interest using the effective interest method prescribed by paragraph 19 of SFAS 91.

The Company has concluded that its description of the interest method used as the simple interest method rather than the effective interest method is not material, and therefore we believe an amendment to the Company’s annual report on Form 10-K is not necessary. The Company proposes to use the following language to note the actual method used in its next filing on Form 10-Q and in subsequent filings on Form 10-K:

Interest on loans is credited to income by the use of the effective interest method.

We appreciate your review and assistance in ensuring our compliance with the applicable disclosure requirements and enhancing the overall disclosure in our filing.

In connection with this response, the Company hereby acknowledges that: the Company 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 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.

Sincerely
/s/ C. Wayne Alderman

Show Raw Text
CORRESP
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filename1.htm

Correspondence

 John P. Nolan, Accounting Branch Chief

 Edwin Adames, Senior Staff Accountant

 United States Securities and Exchange Commission

 Division of Corporation Finance

 Station Place

 100 F St. NE

 Washington DC 20002

Re:
Auburn National Bancorporation, Inc.

 Form 10-K filed
March 31, 2005

 File No. 0-26486

 Dear Messrs. Nolan and Adames,

 Auburn National Bancorporation, Inc. (the “Company”) received your letter dated May 25, 2005 regarding the Securities and Exchange Commissions
Staff’s comments on the above-referenced filing. The Company’s response to the Staff’s comments follows.

 Form 10-K for Year ended December 31, 2004

 Note (1)(e). Summary of Significant Accounting Policies – Loans – page 52

1.
Comment. We refer to the statement that interest on loans is credited to income using the simple interest method. In this regard, explain to us the basis for
using this method to record interest instead of the effective interest method prescribed by paragraph 19 of SFAS 91 computed by calculating a constant effective yield.

 Response. The Company has determined that its statement
regarding the use of the simple interest method did not accurately reflect the method actually used. The Company follows SFAS 91 and records interest using the effective interest method prescribed by paragraph 19 of SFAS 91.

 The Company has concluded that its description of the interest method used as the
simple interest method rather than the effective interest method is not material, and therefore we believe an amendment to the Company’s annual report on Form 10-K is not necessary. The Company proposes to use the following
language to note the actual method used in its next filing on Form 10-Q and in subsequent filings on Form 10-K:

 Interest on loans is credited to income by the use of the effective interest method.

 We appreciate your review and assistance in ensuring our compliance with the
applicable disclosure requirements and enhancing the overall disclosure in our filing.

 In connection with this response, the Company hereby acknowledges that: the Company 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 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.

Sincerely

 /s/ C. Wayne Alderman

 C. Wayne Alderman

 Director of Financial
Operations