SEC Comment Letter for Stock Yards Bancorp, Inc. (SYBT) (CIK 0000835324) (SYBT) — Jun 16, 2009
Stock Yards Bancorp, Inc. (SYBT) (CIK 0000835324)
Date: June 16, 2009 · CIK: 0000835324 · Accession: 0000000000-09-031889
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 001-13661
Referenced dates: June 10, 2009
Letter
UNITED STATES SECURITIES AND EXCHANGE COMMISSION WASHINGTON, D.C. 20549 DIVISION OF CORPORATION FINANCE Mail Stop 4720 June 16, 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 15, 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 June 10, 2009. We are unable to agree with your de termination that the enti re range of performance targets for the CEO and non-line of business EVPs was irrelevant. Please confirm that the company will disclose the entire range of any similar performance targets in future filings.
Nancy B. Davis S.Y. Bancorp, Inc. June 16, 2009 Page 2
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 4720
June 16, 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 15, 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 June 10, 2009. We are
unable to agree with your de termination that the enti re range of performance
targets for the CEO and non-line of business EVPs was irrelevant. Please confirm
that the company will disclose the entire range of any similar performance targets
in future filings.
Nancy B. Davis
S.Y. Bancorp, Inc. June 16, 2009 Page 2
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