SEC Comment Letter 0000000000-24-012801 to Dime Community Bancshares, Inc. /NY/ (DCOM, DCOMG, DCOMP) (CIK 0000846617)
Dime Community Bancshares, Inc. /NY/ (DCOM, DCOMG, DCOMP) (CIK 0000846617)
Date: Nov. 19, 2024 · CIK: 0000846617 · Accession: 0000000000-24-012801
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File numbers found in text: 001-34096
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November 19, 2024
Avinash Reddy
Senior Executive Vice President and Chief Financial Officer
Dime Community Bancshares, Inc.
898 Veterans Memorial Highway, Suite 560
Hauppauge, NY 11788
Re:Dime Community Bancshares, Inc.
Form 10-K for Fiscal Year Ended December 31, 2023
File No. 001-34096
Dear Avinash Reddy:
We have limited our review of your filing to the financial statements and related
disclosures and have the following comment.
Please respond to this letter within ten business days by providing the requested
information or advise us as soon as possible when you will respond. If you do not believe a
comment applies to your facts and circumstances, please tell us why in your response.
After reviewing your response to this letter, we may have additional comments.
Form 10-K for Fiscal Year Ended December 31, 2023
Item 7. Management's Discussion and Analysis of Financial Condition and Results of
Operations
Loan Portfolio Composition, page 32
We note from your tabular disclosure on page 32, that the combination of your
multifamily residential and residential mixed-use, commercial real estate (“CRE”) and
acquisition, development, and construction loans represent a significant portion of
your total loan portfolio as of December 31, 2023. We further note your disclosures
on page 54 including that repayment of multifamily residential loans is dependent, in
significant part, on cash flow from the collateral property sufficient to satisfy
operating expenses and debt service, existing New York City Rent Regulation and
Rent Stabilization laws, and with respect to CRE loans that repayment is often
dependent upon successful operation or management of the collateral properties, as
well as the success of the business and retail tenants occupying the properties. Please
revise future filings to address the following:
1.
November 19, 2024
Page 2
•Further disaggregate the composition of your CRE loan and multifamily
residential and residential mixed-use portfolios at each period end to more clearly
disclose material geographic and other concentrations to the extent material to an
investor’s understanding of credit risk in your loan portfolios. Relevant other
concentrations could include disaggregated disclosure by current weighted
average and/or range of loan-to-value ratios and occupancy rates, if available,
exposure by borrower/collateral type, such as office, retail, hotel, and percentage
of your portfolio subject to rent regulation.
•Describe the specific details of any risk management policies, procedures or other
actions undertaken by management in response to the current multi-family and
commercial real estate environment.
In closing, we remind you that the company and its management are responsible for
the accuracy and adequacy of their disclosures, notwithstanding any review, comments,
action or absence of action by the staff.
Please contact Victor Cecco at 202-551-2064 or Michael Volley at 202-551-3437
with any questions.
Sincerely,
Division of Corporation Finance
Office of Finance