SEC Comment Letter for Stock Yards Bancorp, Inc. (SYBT) (CIK 0000835324) (SYBT) — Jun 10, 2009
Stock Yards Bancorp, Inc. (SYBT) (CIK 0000835324)
Date: June 10, 2009 · CIK: 0000835324 · Accession: 0000000000-09-031011
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 001-13661
Referenced dates: May 26, 2009
Letter
UNITED STATES SECURITIES AND EXCHANGE COMMISSION WASHINGTON, D.C. 20549 DIVISION OF CORPORATION FINANCE Mail Stop 4561 June 10, 2009 By U.S. Mail and Facsimile to: (502) 625-2295 Nancy B. Davis Executive Vice President, Treasurer and Chief Financial Officer S.Y. Bancorp, Inc. 1040 East Main Street Louisville, Kentucky 40206
Re: S.Y. Bancorp, Inc. Form 10-K for the Fiscal Year Ended December 31, 2008 Filed March 13, 2009 File No. 001-13661
Dear Ms. Davis:
We have reviewed your response filed with the Commission on June 5, 2009 and have the following comment. Where i ndicated, we think you should revise your documents in response to this comment. If you disagree, we will consider your explanation as to why our comment is inappl icable or a revision is unnecessary. Please be as detailed as necessary in your explan ation. In our comment, 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. We welcome any questions you may have about our comment or any other aspect of our review. Feel free to call us at the te lephone numbers listed at the end of this letter.
Form 10-K for the Fiscal Year Ended December 31, 2008
Item 11. Executive Compensation, page 79
Specific Elements of Compen sation, and How Performance Impacts Each, page 13 of Definitive Proxy Statement on Schedule 14A 1. We note your response to comment 1 in our letter dated May 26, 2009. We also note that you disclose the threshold performance targets for the annual cash incentive awards for three of your name d executive officers, and in prior years you disclosed the entire range of performa nce targets for these three officers. Please tell us why your competitive harm argument is applicable to Messrs. Hillebrand and Poindexter and not the other named executive officers. Please
Nancy B. Davis S.Y. Bancorp, Inc. June 10, 2009 Page 2
also tell us the basis for your decision to report only the thre shold targets for the other three named executive officers, rather than the entire range of performance targets as disclosed in prior years.
Closing Comments
Please respond to this comment within 10 business days or tell us when you will provide us with a response. Please furnish a cover letter that keys your response to our comment and provides any requested information. Detailed cover lette rs greatly facilitate our review. Please understand that we may have additional commen ts after reviewing your response to our comment.
Please contact Justin Dobbie at (202) 551-3469 or me at (202) 551-3464 with any questions.
Sincerely,
Kathryn McHale Staff Attorney
Show Raw Text
UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549
DIVISION OF
CORPORATION FINANCE
Mail Stop 4561
June 10, 2009
By U.S. Mail and Facsimile to: (502) 625-2295
Nancy B. Davis Executive Vice President, Treasurer and Chief Financial Officer S.Y. Bancorp, Inc. 1040 East Main Street Louisville, Kentucky 40206
Re: S.Y. Bancorp, Inc.
Form 10-K for the Fiscal Year Ended December 31, 2008
Filed March 13, 2009
File No. 001-13661
Dear Ms. Davis:
We have reviewed your response filed with the Commission on June 5, 2009 and
have the following comment. Where i ndicated, we think you should revise your
documents in response to this comment. If you disagree, we will consider your explanation as to why our comment is inappl icable or a revision is unnecessary. Please
be as detailed as necessary in your explan ation. In our comment, 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.
We welcome any questions you may have about our comment or any other aspect
of our review. Feel free to call us at the te lephone numbers listed at the end of this letter.
Form 10-K for the Fiscal Year Ended December 31, 2008
Item 11. Executive Compensation, page 79
Specific Elements of Compen sation, and How Performance Impacts Each, page 13 of
Definitive Proxy Statement on Schedule 14A
1. We note your response to comment 1 in our letter dated May 26, 2009. We also
note that you disclose the threshold performance targets for the annual cash
incentive awards for three of your name d executive officers, and in prior years
you disclosed the entire range of performa nce targets for these three officers.
Please tell us why your competitive harm argument is applicable to Messrs.
Hillebrand and Poindexter and not the other named executive officers. Please
Nancy B. Davis
S.Y. Bancorp, Inc. June 10, 2009 Page 2
also tell us the basis for your decision to report only the thre shold targets for the
other three named executive officers, rather than the entire range of performance
targets as disclosed in prior years.
Closing Comments
Please respond to this comment within 10 business days or tell us when you will
provide us with a response. Please furnish a cover letter that keys your response to our
comment and provides any requested information. Detailed cover lette rs greatly facilitate
our review. Please understand that we may have additional commen ts after reviewing
your response to our comment.
Please contact Justin Dobbie at (202) 551-3469 or me at (202) 551-3464 with any
questions.
Sincerely,
Kathryn McHale Staff Attorney