SEC Comment Letter for COLUMBIA BANCORP (CIK 0000834105) — Aug 3, 2005
COLUMBIA BANCORP (CIK 0000834105)
Date: Aug. 3, 2005 · CIK: 0000834105 · Accession: 0000000000-05-039991
AI Filing Summary & Sentiment
Letter
August 3, 2005 Mail Stop 4561 John M. Bond Jr. Chairman and Chief Executive Officer Columbia Bancorp 7168 Columbia Gateway Drive Columbia, MD 21046
Re: Columbia Bancorp Form 10-K for the period ended December 31, 2004 File No. 0-24302
Dear Mr. Bond:
We have reviewed your filing and have the following comments. We have limited our review of your filing to those issues we have addressed in our comments. 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
Financial Statements
Consolidated Statements of Cash Flows, page 46
1. We note that you sold loans held for investment purposes during each of the years ended December 31, 2004, 2003 and 2002. Please tell us the following:
* The nature of the loans sold;
* The reasons for the sales; and
* Why these loans were not classified as loans held for sale.
Note 1- Summary of Significant Accounting Policies
Investment Securities Held-to-Maturity and Available-for-Sale, page
2. We note your disclosures that the carrying values of securities held-to-maturity and available-for-sale are adjusted for premium amortization to the earlier of the maturity or expected call date and discount accretion to the maturity date. Please tell us the following:
* The method you use to amortize premiums and discounts into interest income;
* Separately quantify premiums and discounts amortized into interest income during each period presented;
* Why you use the earlier of the maturity or expected call date for premium amortization but the maturity date for discount accretion.
As appropriate, please respond to these comments within 10 business days or tell us when you will provide us with a response. Please furnish a response letter that keys your responses to our comments and provides any requested information. Detailed letters greatly facilitate our review. Please file your response letter on EDGAR. Please understand that we may have additional comments after reviewing your 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 Sharon Johnson, Staff Accountant, at (202) 551- or me at (202) 551-3449 if you have questions.
Sincerely,
Joyce Sweeney
Branch Chief
Show Raw Text
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<TEXT>
August 3, 2005
Mail Stop 4561
John M. Bond Jr.
Chairman and Chief Executive Officer
Columbia Bancorp
7168 Columbia Gateway Drive
Columbia, MD 21046
Re: Columbia Bancorp
Form 10-K for the period ended December 31, 2004
File No. 0-24302
Dear Mr. Bond:
We have reviewed your filing and have the following
comments.
We have limited our review of your filing to those issues we have
addressed in our comments. 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
Financial Statements
Consolidated Statements of Cash Flows, page 46
1. We note that you sold loans held for investment purposes during
each of the years ended December 31, 2004, 2003 and 2002. Please
tell us the following:
* The nature of the loans sold;
* The reasons for the sales; and
* Why these loans were not classified as loans held for sale.
Note 1- Summary of Significant Accounting Policies
Investment Securities Held-to-Maturity and Available-for-Sale,
page
51
2. We note your disclosures that the carrying values of securities
held-to-maturity and available-for-sale are adjusted for premium
amortization to the earlier of the maturity or expected call date
and
discount accretion to the maturity date. Please tell us the
following:
* The method you use to amortize premiums and discounts into
interest
income;
* Separately quantify premiums and discounts amortized into
interest
income during each period presented;
* Why you use the earlier of the maturity or expected call date
for
premium amortization but the maturity date for discount accretion.
As appropriate, please respond to these comments within 10
business days or tell us when you will provide us with a response.
Please furnish a response letter that keys your responses to our
comments and provides any requested information. Detailed letters
greatly facilitate our review. Please file your response letter
on
EDGAR. Please understand that we may have additional comments
after
reviewing your 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 Sharon Johnson, Staff Accountant, at (202) 551-
3474
or me at (202) 551-3449 if you have questions.
Sincerely,
Joyce Sweeney
Branch Chief
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John M. Bond Jr.
Columbia Bancorp
August 3, 2005
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