SEC Comment Letter for FIRST UNITED (FUNC) — Jun 2, 2020
FIRST UNITED CORP/MD/ (FUNC) (CIK 0000763907)
Date: June 2, 2020 · CIK: 0000763907 · Accession: 0000000000-20-004913
AI Filing Summary & Sentiment
File numbers found in text: 000-14237
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UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549
DIVISION OF
CORPORATION FINANCE
June 2 , 2020
Carissa L. Rodeheaver
Chairman of the Board, President and CEO
First United Corporation
19 S Second Street
Oakland, MD 21550
Re: First United Corporation
DEFA1 4A filed by First United Corporation
Filed June 2 , 2020
File No. 000-14237
Dear Ms. Rodeheaver :
We have reviewed the above -captioned filing, and have the following comments. Some
of our comments may ask for additional information so we may be tter understand the disclosure.
Please respond to this letter by amending the filing and/or by providing the requested
information. If you do not believe our comments apply to your facts and circumstances and/or
do not believe an amendment is appropriate, please tel l us why in a written response.
After reviewing any amendment to the filing and any information provided in response to
these comments, we may have additional comments.
Definitive Additional Materials filed under cover of Sch edule 14A
1. Notwithstanding the fact the registrant purportedly is sending a letter advising shareholders
of the change in the location and format of the annual meeting, the definitive proxy statement
filed on April 17, 2020 represented a different location and format. To the extent the location
and format published in the definitive proxy statemen t is considered a material fact , the
definitive proxy statement needs to be amended in order to reflect this change and ensure
compliance with Rule 14a -9. The cover page of any supplement to the definitive proxy
statement should be designated as “Amendment No. 1 ” and the box referring to the
“Definitive Proxy Statement ” should b e checked. In addition, the EDGAR header tag
“DEFR14A ” should be used. See 17 CFR §232.301 within Regulation S -T.
* * *
Carissa L. Rodeheaver
June 2 , 2020
Page 2
We remind you that the registrant is responsible for the accuracy and adequacy of its
disclosures, notwiths tanding any review, comments, action or absence of action by the staff.
You may contact me at (202) 551 -3266 with any questions.
Sincerely,
/s/ Nicholas P. Panos
Nicholas P. Panos
Senior Special Counsel
Office of Mergers and Acquisitions
cc: Lawrence S. Elbaum, Esq.