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SEC Comment Letter for SOUTH FINANCIAL GROUP INC (CIK 0000797871) — Aug 31, 2005

SOUTH FINANCIAL GROUP INC (CIK 0000797871)
Date: Aug. 31, 2005 · CIK: 0000797871 · Accession: 0000000000-05-045200

AI Filing Summary & Sentiment

File numbers found in text: 000-15083

Date
August 31, 2005
Author
Brian Cascio
Form
UPLOAD
Company
SOUTH FINANCIAL GROUP INC (CIK 0000797871)

Letter

August 31, 2005 Via U.S. Mail and Facsimile Mr. William S. Hummers III Executive Vice President and Chief Financial Officer The South Financial Group, Inc. 102 Main Street Greenville, SC 29601

Re: The South Financial Group, Inc. Form 10-K for the Fiscal Year Ended December 31, 2004 Filed March 15, 2005 File No. 000-15083

Dear Mr. Hummers:

We have limited our review of your filing to those issues we have addressed in our comments. Where indicated, we think you should revise your document in response to these comments. 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 some of our comments, we may ask you to provide us with information so we may better understand your disclosure. After reviewing this information, we may 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 comments 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 for the Fiscal Year Ended December 31, 2004

Item 8. Financial Statements and Supplementary Data

Report of Independent Registered Public Accounting Firm

1. The audit report on Management`s Report on Internal Control over Financial Reporting included in the Form 10-K filed in EDGAR is not signed. Please amend to include an audit report that includes the conformed signature of your independent auditor. Refer to Regulation S-X, Article 2.

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 information. Detailed cover letters greatly facilitate our review. When sending supplemental information regarding this filing, please include the following ZIP+4 code in our address: 20549-6010. 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 to be certain that the filing includes all information required under the Securities Exchange Act of 1934 and that they have provided all information investors require for an informed investment 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 Lynn Dicker at (202) 551-3616 or me at (202) 551-3676 if you have questions regarding comments on the financial statements and related matters. In this regard, do not hesitate to contact Martin James, Senior Assistant Chief Accountant, at (202) 551-3671.

Sincerely,
Brian Cascio
Accounting Branch Chief

Show Raw Text
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<TEXT>

Mail Stop 6010

								August 31, 2005

Via U.S. Mail and Facsimile

Mr. William S. Hummers III
Executive Vice President and Chief Financial Officer
The South Financial Group, Inc.
102 Main Street
Greenville, SC 29601

Re:	The South Financial Group, Inc.
	Form 10-K for the Fiscal Year Ended December 31, 2004
      Filed March 15, 2005
	File No. 000-15083

Dear Mr. Hummers:

      We have limited our review of your filing to those issues we
have addressed in our comments.  Where indicated, we think you
should
revise your document in response to these comments.  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 some of our comments, we may
ask
you to provide us with information so we may better understand
your
disclosure.  After reviewing this information, we may 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 comments 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 for the Fiscal Year Ended December 31, 2004

Item 8. Financial Statements and Supplementary Data

Report of Independent Registered Public Accounting Firm

1. The audit report on Management`s Report on Internal Control
over
Financial Reporting included in the Form 10-K filed in EDGAR is
not
signed.  Please amend to include an audit report that includes the
conformed signature of your independent auditor.  Refer to
Regulation
S-X, Article 2.

       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 information.  Detailed cover letters
greatly
facilitate our review.  When sending supplemental information
regarding this filing, please include the following ZIP+4 code in
our
address: 20549-6010.  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 to be certain that the
filing includes all information required under the Securities
Exchange Act of 1934 and that they have provided all information
investors require for an informed investment 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 Lynn Dicker at (202) 551-3616 or me at (202)
551-3676 if you have questions regarding comments on the financial
statements and related matters.  In this regard, do not hesitate
to
contact Martin James, Senior Assistant Chief Accountant, at (202)
551-3671.

      Sincerely,

Brian Cascio
Accounting Branch Chief

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Mr. William S. Hummers III
The South Financial Group, Inc.
August 31, 2005
Page 2

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</DOCUMENT>