SEC Comment Letter for SouthState Corp (SSB) (CIK 0000764038) (SSB) — Nov 4, 2009
SouthState Corp (SSB) (CIK 0000764038)
Date: Nov. 4, 2009 · CIK: 0000764038 · Accession: 0000000000-09-062515
AI Filing Summary & Sentiment
File numbers found in text: 001-12669
Letter
UNITED STATES SECURITIES AND EXCHANGE COMMISSION WASHINGTON, D.C. 20549 DIVISION OF CORPORATION FINANCE Mail Stop 4720 November 4, 2009 Robert R. Hill, Jr. President and Chief Executive Officer SCBT Financial Corporation 520 Gervais Street Columbia, SC 29201
Re: SCBT Financial Corporation Form 10-Q for Fiscal Quarter Ended June 30, 2009 File No. 001-12669
Dear Mr. Hill:
We have reviewed your response dated August 14, 2009 and have the following comments. Where indicated, we think you should revise your disclosure in response to these comments. If you disagree, we will consider your explanation as to why our comments are inapplicable or a revision is unnecessary. Please be as detailed as necessary in your explanation. In some of our comments, we may ask you to provide us with information so we may better understand your disclosure. Af ter reviewing this information, we may raise additional comments.
Form 10-Q for Fiscal Quarter Ended June 30, 2009
Note 3 – Investments, page 7
1. Consistent with the guidance in paragraphs 10 and 12 of FSP EITF 99-20-1 and 25 and 26 of FSP 115-2, we believe you must look at the specific collateral underlying each individual security to de velop the credit defe rral assumptions for your estimated cash flows and that simply using the same general deferral assumption for every pooled trust preferre d security you hold is not a reasonable methodology consistent with the guidance. Therefore, please revise your OTTI methodology for these securities to use the specific collateral underlying each security as the basis for your credit defe rral/default assumptions or provide us with an analysis that supports that the difference in credit loss is not material. In addition, if you intend to change your OTTI methodology going forward, please clearly disclose this po licy in future filings.
Robert R. Hill, Jr. SCBT Financial Corporation November 4, 2009 Page 2 * * * * * Please respond to these comments within 10 business days or tell us when you will provide us with a response. Please furnish a cover letter that keys your responses to our comments and provides any requested in formation. Detailed cover letters greatly facilitate our review. Please understand th at we may have additional comments after reviewing your responses to our comments. Please contact Babette Cooper, Staff A ccountant, at (202) 551-3396 or me at (202) 551-3492 if you have any questions. Sincerely, John P. Nolan Senior Assistant Chief Accountant
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UNITED STATES SECURITIES AND EXCHANGE COMMISSION WASHINGTON, D.C. 20549 DIVISION OF CORPORATION FINANCE Mail Stop 4720 November 4, 2009 Robert R. Hill, Jr. President and Chief Executive Officer SCBT Financial Corporation 520 Gervais Street Columbia, SC 29201 Re: SCBT Financial Corporation Form 10-Q for Fiscal Quarter Ended June 30, 2009 File No. 001-12669 Dear Mr. Hill: We have reviewed your response dated August 14, 2009 and have the following comments. Where indicated, we think you should revise your disclosure in response to these comments. If you disagree, we will consider your explanation as to why our comments are inapplicable or a revision is unnecessary. Please be as detailed as necessary in your explanation. In some of our comments, we may ask you to provide us with information so we may better understand your disclosure. Af ter reviewing this information, we may raise additional comments. Form 10-Q for Fiscal Quarter Ended June 30, 2009 Note 3 – Investments, page 7 1. Consistent with the guidance in paragraphs 10 and 12 of FSP EITF 99-20-1 and 25 and 26 of FSP 115-2, we believe you must look at the specific collateral underlying each individual security to de velop the credit defe rral assumptions for your estimated cash flows and that simply using the same general deferral assumption for every pooled trust preferre d security you hold is not a reasonable methodology consistent with the guidance. Therefore, please revise your OTTI methodology for these securities to use the specific collateral underlying each security as the basis for your credit defe rral/default assumptions or provide us with an analysis that supports that the difference in credit loss is not material. In addition, if you intend to change your OTTI methodology going forward, please clearly disclose this po licy in future filings. Robert R. Hill, Jr. SCBT Financial Corporation November 4, 2009 Page 2 * * * * * Please respond to these comments within 10 business days or tell us when you will provide us with a response. Please furnish a cover letter that keys your responses to our comments and provides any requested in formation. Detailed cover letters greatly facilitate our review. Please understand th at we may have additional comments after reviewing your responses to our comments. Please contact Babette Cooper, Staff A ccountant, at (202) 551-3396 or me at (202) 551-3492 if you have any questions. Sincerely, John P. Nolan Senior Assistant Chief Accountant