SEC Comment Letter 0000000000-23-013389 to MID PENN BANCORP INC (MPB) (CIK 0000879635) (MPB)
MID PENN BANCORP INC (MPB) (CIK 0000879635)
Date: Dec. 7, 2023 · CIK: 0000879635 · Accession: 0000000000-23-013389
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 001-13677
Letter
United States securities and exchange commission logo December 7, 2023 Allison Johnson Chief Financial Officer Mid Penn Bancorp, Inc. 2407 Park Drive Harrisburg, PA 17110 Re:Mid Penn Bancorp, Inc. Form 10-K for Fiscal Year Ended December 31, 2022 Filed March 16, 2023 File No. 001-13677 Dear Allison Johnson: 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 filed March 16, 2023 Item 7. Management's Discussion and Analysis of Financial Condition and Results of Operations Loans, page 40 1.We note the tabular disclosure on page 40 detailing the composition of your gross loan portfolio, which includes commercial real estate (“CRE”). Given the significance of CRE in your total loan portfolio, please revise your disclosures, in future filings, to further disaggregate the composition of your CRE loan portfolio by separately presenting owner and non-owner occupied, by borrower type (e.g., by office, hotel, multifamily, etc.), geographic concentrations and other characteristics (e.g., current weighted average and/or range of loan-to-value ratios, occupancy rates, etc.) material to an investor’s understanding of your CRE loan portfolio. In addition, revise to describe the specific details of any risk management policies, procedures or other actions undertaken by management in response to the current environment. In closing, we remind you that the company and its management are responsible for the
FirstName LastNameAllison Johnson Comapany NameMid Penn Bancorp, Inc. December 7, 2023 Page 2 FirstName LastName Allison Johnson Mid Penn Bancorp, Inc. December 7, 2023 Page 2 accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the staff. Please contact William Schroeder at 202-551-3294 or Amit Pande at 202-551-3423 with any questions. Sincerely, Division of Corporation Finance Office of Finance
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United States securities and exchange commission logo
December 7, 2023
Allison Johnson
Chief Financial Officer
Mid Penn Bancorp, Inc.
2407 Park Drive
Harrisburg, PA 17110
Re:Mid Penn Bancorp, Inc.
Form 10-K for Fiscal Year Ended December 31, 2022
Filed March 16, 2023
File No. 001-13677
Dear Allison Johnson:
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 filed March 16, 2023
Item 7. Management's Discussion and Analysis of Financial Condition and Results of Operations
Loans, page 40
1.We note the tabular disclosure on page 40 detailing the composition of your gross loan
portfolio, which includes commercial real estate (“CRE”). Given the significance of CRE
in your total loan portfolio, please revise your disclosures, in future filings, to further
disaggregate the composition of your CRE loan portfolio by separately presenting owner
and non-owner occupied, by borrower type (e.g., by office, hotel, multifamily, etc.),
geographic concentrations and other characteristics (e.g., current weighted average and/or
range of loan-to-value ratios, occupancy rates, etc.) material to an investor’s
understanding of your CRE loan portfolio. In addition, revise to describe the specific
details of any risk management policies, procedures or other actions undertaken by
management in response to the current environment.
In closing, we remind you that the company and its management are responsible for the
FirstName LastNameAllison Johnson
Comapany NameMid Penn Bancorp, Inc.
December 7, 2023 Page 2
FirstName LastName
Allison Johnson
Mid Penn Bancorp, Inc.
December 7, 2023
Page 2
accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or
absence of action by the staff.
Please contact William Schroeder at 202-551-3294 or Amit Pande at 202-551-3423 with
any questions.
Sincerely,
Division of Corporation Finance
Office of Finance