SEC Comment Letter for MERCHANTS & MANUFACTURERS BANCORPORATION INC (CIK 0000753682) — Jul 14, 2005
MERCHANTS & MANUFACTURERS BANCORPORATION INC (CIK 0000753682)
Date: July 14, 2005 · CIK: 0000753682 · Accession: 0000000000-05-036064
AI Filing Summary & Sentiment
File numbers found in text: 000-21292
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<TYPE>LETTER
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<FILENAME>filename1.txt
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July 14, 2005
Mail Stop 4561
By U.S. Mail and facsimile to (262) 796-8158
Mr. Michael J. Murry
Chairman and Principal Executive Officer
Merchants and Manufacturers Bancorporation, Inc.
5445 South Westridge Drive,
New Berlin, Wisconsin 53151
Re: Merchants and Manufacturers Bancorporation, Inc.
Form 10-K for the fiscal year ended December 31, 2004
Filed March 16, 2005
File Number: 000-21292
Dear Mr. Murry:
We have reviewed your filing and have the following comment.
Where indicated, we think you should revise your document in
response
to this comment. If you disagree, we will consider your
explanation
as to why our comment is inapplicable or a revision is
unnecessary.
Please be as detailed as necessary in your explanation. In our
comment, we may ask you to provide us with supplemental
information
so we may better understand your disclosure. After reviewing this
information, we may or may not raise additional comments.
Please understand that the purpose of our review process is
to
assist you in your compliance with the applicable disclosure
requirements and to enhance the overall disclosure in your filing.
We look forward to working with you in these respects. We welcome
any questions you may have about our comment or any other aspect
of
our review. Feel free to call us at the telephone numbers listed
at
the end of this letter.
Form 10-K, filed on March 16, 2005
Notes to Consolidated Financial Statements
Note 14. Income Taxes, page 30
1. We note in your table on page 31 that you have a deferred tax
asset valuation allowance equal to your net operating loss
carryforwards for each period presented. Please tell us the
following:
* Explain what your net operating loss carryforwards are
attributable
to and when they are expected to expire. Refer to the disclosure
requirements prescribed by paragraph 48 of SFAS 109;
* Provide us with the analysis you performed that led you to
conclude
that it is more likely than not that these net operating loss
carryforwards will not be realized. Refer to the authoritative
guidance included in paragraph 17(e) of SFAS 109;
* * * * *
As appropriate, please amend your filing and respond to
these
comments within 10 business days or tell us when you will provide
us
with a response. You may wish to provide us with marked copies of
the amendment to expedite our review. Please furnish a cover
letter
with your amendment that keys your responses to our comments and
provides any requested supplemental information. Detailed cover
letters greatly facilitate our review. Please understand that we
may
have additional comments after reviewing your amendment and
responses
to our comments.
We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filing reviewed by the staff to
be
certain that they have provided all information investors require
for
an informed decision. Since the company and its management are in
possession of all facts relating to a company`s disclosure, they
are
responsible for the accuracy and adequacy of the disclosures they
have made.
In connection with responding to our comments, please
provide,
in writing, a 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.
In addition, please be advised that the Division of
Enforcement
has access to all information you provide to the staff of the
Division of Corporation Finance in our review of your filing or in
response to our comments on your filing.
You may contact John Spitz at (202) 551-3484 or me at (202)
551-3490 if you have questions.
Sincerely,
Donald Walker
Senior Assistant Chief Accountant
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Mr. Michael J. Murry
Merchants and Manufacturers Bancorporation, Inc..
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