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SEC Comment Letter for CALIFORNIA FIRST LEASING CORP (CFNB) (CIK 0000803016) (CFNB) — Mar 1, 2010

CALIFORNIA FIRST LEASING CORP (CFNB) (CIK 0000803016)
Date: March 1, 2010 · CIK: 0000803016 · Accession: 0000000000-10-011572

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File numbers found in text: 000-15641

Referenced dates: February 3, 2010

Date
March 1, 2010
Author
Paul Cline
Form
UPLOAD
Company
CALIFORNIA FIRST LEASING CORP (CFNB) (CIK 0000803016)

Letter

DIVISION OF CORPORATION FINANCE UNITED STATES SECURITIES AND EXCHANGE COMMISSION WASHINGTON, D.C. 20549 March 1, 2010 S. Leslie Jewett Chief Financial Officer California First National Bancorp 18201 Von Karman, Suite 800 Irvine, CA 92612 Re: California First National Bancorp Form 10-K for Fiscal Period Ended June 30, 2009 Form 10-Q for Fiscal Period Ended September 30, 2009 File No. 000-15641

Dear Ms. Jewett:

We have reviewed your filing and have the following comments. Where indicated, we think you should revise your doc ument in response to these comments in future filings. 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. 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 th ese 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. 1. Please refer to our previous comment 1 in our letter dated February 3, 2010. Please tell us the following information:

a. In your response you state that you ev aluate all loans on an individual basis, but determine a general component of the allowance for loan losses in part by relying on historical data. Please clarify whether you are evaluating these loans under both ASC 450 and ASC 310-10-35. If so, please provide the accounting guidan ce relied on when determining that this policy is appropriate.

S. Leslie Jewett California First National Bancorp March 1, 2010 Page 2 b. Please tell us specifically the extent to which you rely on loss history from your lease portfolio when determin ing the general component of your allowance for loan losses. We note your disclosure on page 2 of the Form 10-K for Fiscal Period Ended June 3 0, 2009 that your leases are primarily collateralized by technology equipment, other property and equipment and software. We further note on page 5 that your commercial loans have various collateral sources such as mortgages, receivables or equipment. In light of these disclosures, please tell us how you de termined that the risk characteristics of your leases were similar to your commercial loans and how you concluded that reliance on this data is appropriate.

c. Please tell us the nature of the FDIC data utilized in your estimate of the general component. Please provide additional detail regarding the types of adjustments made to your baseline and clarify what you mean by this statement. 2. Please refer to our previous comments 4- 6 in our letter dated February 3, 2010. As requested, please provide us with your proposed disclosures. 3. Please revise your income statement to pres ent a measure of net interest income. Refer to Article 9 of Regulation S-X. Closing Comments

As appropriate, please respond to these co mments within 10 business days or tell us when you will provide us with a response. Please provide us with copies of your proposed revisions to your future filings . Please furnish a cover letter with your amendment that keys your responses to our comments and provides any requested information. Detailed cover le tters greatly facilitate our re view. Please understand that we may have additional comments after re viewing your responses to our comments.

You may contact Rebekah M oore, Staff Accountant, at (202) 551-3303, or me, at (202) 551-3851 if you have questions regarding these comments. Sincerely,

Paul Cline Senior Staff Accountant

Show Raw Text
DIVISION OF
CORPORATION FINANCE   UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549

March 1, 2010
 S. Leslie Jewett Chief Financial Officer California First National Bancorp 18201 Von Karman, Suite 800 Irvine, CA 92612
Re: California First National Bancorp  Form 10-K for Fiscal Period Ended June 30, 2009
Form 10-Q for Fiscal Period Ended September 30, 2009
 File No. 000-15641

Dear Ms. Jewett:

We have reviewed your filing and have the following comments.  Where
indicated, we think you should revise your doc ument in response to these comments in
future filings.  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.   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 th ese 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.
1. Please refer to our previous comment 1 in our letter dated February 3, 2010.  Please tell us the following information:

a. In your response you state that you ev aluate all loans on an individual
basis, but determine a general component of the allowance for loan losses
in part by relying on historical data.  Please clarify whether you are evaluating these loans under both ASC 450 and ASC 310-10-35.  If so, please provide the accounting guidan ce relied on when determining that
this policy is appropriate.

S. Leslie Jewett
California First National Bancorp March 1, 2010 Page 2
b. Please tell us specifically the extent to  which you rely on loss history from
your lease portfolio when determin ing the general component of your
allowance for loan losses.   We note your disclosure on page 2 of the Form 10-K for Fiscal Period Ended June 3 0, 2009 that your leases are primarily
collateralized by technology equipment,  other property and equipment and
software.  We further note on page 5 that your commercial loans have
various collateral sources such as mortgages, receivables or equipment.  In light of these disclosures,  please tell us how you de termined that the risk
characteristics of your leases were similar to your commercial loans and
how you concluded that reliance on this data is appropriate.

c. Please tell us the nature of the FDIC data utilized  in your estimate of the
general component.  Please provide additional detail regarding the types of adjustments made to your baseline and clarify what you mean by this statement.
2. Please refer to our previous comments 4- 6 in our letter dated February 3, 2010.
As requested, please provide us with your proposed disclosures.
3. Please revise your income statement to pres ent a measure of net interest income.
Refer to Article 9 of Regulation S-X.
 Closing Comments

 As appropriate, please respond to these co mments within 10 business days or tell
us when you will provide us with a response.  Please provide us with copies of your
proposed revisions to your future filings .  Please furnish a cover letter with your
amendment that keys your responses to our comments and provides any requested
information.  Detailed cover le tters greatly facilitate our re view.  Please understand that
we may have additional comments after re viewing your responses to our comments.

You may contact Rebekah M oore, Staff Accountant, at  (202) 551-3303, or me, at
(202) 551-3851 if you have questions regarding these comments.
Sincerely,

Paul Cline Senior Staff Accountant