SEC Comment Letter for CITIZENS BANCSHARES — Sep 14, 2005
CITIZENS BANCSHARES CORP /GA/ (CIK 0000813640)
Date: Sept. 14, 2005 · CIK: 0000813640 · Accession: 0000000000-05-047541
AI Filing Summary & Sentiment
File numbers found in text: 000-14535
Referenced dates: August 16, 2005, August 30, 2005
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<TYPE>LETTER
<SEQUENCE>1
<FILENAME>filename1.txt
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Mail Stop 4561
September 8, 2005
By U.S. Mail and facsimile to 404-653-2877
Samuel J. Cox
Chief Financial Officer
Citizens Bancshares Corporation
75 Piedmont Avenue, N.E.,
Atlanta, Georgia 30302
Re: Citizens Bancshares Corporation
Form 10-K for the Fiscal Year Ended December 31, 2004
Forms 10-Q for the Quarters Ended March 31, 2005 and June 30, 2005
File No. 000-14535
Dear Mr. Cox:
We have reviewed your response letter dated August 30, 2005
and
have the following additional comments.
Form 10-K for the Fiscal Year Ended December 31, 2004
Note 8 - Income Taxes, page 61
1. We note your supplemental response to comment 1 of our letter
dated August 16, 2005. Please provide us with a full analysis
comparing and explaining the differences between the information
contained in your Form 10-K for the fiscal year ended December 31,
2004 and what was uncovered by your auditors to demonstrate a
valuation allowance was not needed as of December 31, 2004.
Form 10-Q for the Fiscal Quarter Ended June 30, 2005
Management`s Discussion and Analysis - Investment Securities, page
13
2. We note your supplemental response to comment 2 of our letter
dated August 16, 2005. In view of the continuing decline of your
agency preferred securities and fact they have no maturity date,
please tell us your expected period of time sufficient for a
recovery
of fair value and how you determined your projections as of
December
31, 2002, 2003 and 2004.
* * * * *
Please respond to these comments within 10 business days or
tell us when you will provide us with a response. Please file
your
response on EDGAR. Detailed cover letters greatly facilitate our
review. Please understand that we may have additional comments
after
reviewing your amendment and responses to our comments.
You may contact Matthew Komar (Staff Accountant) at (202)
551-
3781 or me at (202) 551-3490 if you have questions regarding
comments on the financial statements and related matters.
Sincerely,
Don Walker
Senior Assistant
Chief Accountant
Samuel J. Cox
Citizens Bancshares Corporation
September 8, 2005
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