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SEC Comment Letter 0000000000-24-007104 to Atlantic Union Bankshares Corp (AUB, AUB-PA) (CIK 0000883948) (AUB)

Atlantic Union Bankshares Corp (AUB, AUB-PA) (CIK 0000883948)
Date: June 24, 2024 · CIK: 0000883948 · Accession: 0000000000-24-007104

AI Filing Summary & Sentiment

File numbers found in text: 001-39325

Date
June 24, 2024
Author
Office of Finance
Form
UPLOAD
Company
Atlantic Union Bankshares Corp (AUB, AUB-PA) (CIK 0000883948)

Letter

United States securities and exchange commission logo June 24, 2024 Robert M. Gorman Chief Financial Officer Atlantic Union Bankshares Corporation 4300 Cox Road Glen Allen, VA 23060 Re:Atlantic Union Bankshares Corporation Form 10-K for Fiscal Year Ended December 31, 2023 File No. 001-39325 Dear Robert M. Gorman: We have limited our review of your filing to the financial statements and related disclosures and have the following comments. 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 Management's Discussion and Analysis of Financial Condition and Results of Operations Loan Portfolio, page 61 1.We note your disclosure that commercial real estate (“CRE”) loans represented one of your largest loan categories at December 31, 2023 and 2022. We also note that non-owner occupied CRE loans comprised 26.7% of your total loans held for investment (“LHFI”) as of December 31, 2023. Additionally, we note that the Appendix to your Earnings Presentation included in Exhibit 99.2 to your Form 8-K filed on January 23, 2024 provides additional quantitative information about the composition of your non-owner occupied CRE portfolio. Please revise your future periodic filings to further disaggregate the composition of your total CRE loan portfolio 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 CRE loan portfolio. Relevant other concentrations could include disaggregated disclosure by borrower/collateral type (e.g., office, hotel, retail, etc.) similar to the information provided in your Earnings Presentation, or by geographic market, and an average and range of loan-to-value ratios.

FirstName LastNameRobert M. Gorman Comapany NameAtlantic Union Bankshares Corporation June 24, 2024 Page 2 FirstName LastName Robert M. Gorman Atlantic Union Bankshares Corporation June 24, 2024 Page 2 2.In addition, we note your disclosure on page 18 that CRE loans also typically have larger loan balances, and, therefore, the deterioration of one or a few of these loans could cause a significant increase in the percentage of your non-performing loans. Please revise your future periodic filings to clarify any specific risk management policies, procedures or other actions undertaken by management that address the current CRE 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 Katharine Garrett at 202-551-2332 or John Spitz at 202-551-3484 with any questions. Sincerely, Division of Corporation Finance Office of Finance

Show Raw Text
United States securities and exchange commission logo
June 24, 2024
Robert M. Gorman
Chief Financial Officer
Atlantic Union Bankshares Corporation
4300 Cox Road
Glen Allen, VA 23060
Re:Atlantic Union Bankshares Corporation
Form 10-K for Fiscal Year Ended December 31, 2023
File No. 001-39325
Dear Robert M. Gorman:
            We have limited our review of your filing to the financial statements and related
disclosures and have the following comments.
            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
Management's Discussion and Analysis of Financial Condition and Results of Operations
Loan Portfolio, page 61
1.We note your disclosure that commercial real estate (“CRE”) loans represented one of
your largest loan categories at December 31, 2023 and 2022. We also note that non-owner
occupied CRE loans comprised 26.7% of your total loans held for investment (“LHFI”) as
of December 31, 2023. Additionally, we note that the Appendix to your Earnings
Presentation included in Exhibit 99.2 to your Form 8-K filed on January 23, 2024
provides additional quantitative information about the composition of your non-owner
occupied CRE portfolio. Please revise your future periodic filings to further disaggregate
the composition of your total CRE loan portfolio 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 CRE loan portfolio. Relevant other
concentrations could include disaggregated disclosure by borrower/collateral type (e.g.,
office, hotel, retail, etc.) similar to the information provided in your Earnings Presentation,
or by geographic market, and an average and range of loan-to-value ratios.

 FirstName LastNameRobert M. Gorman
 Comapany NameAtlantic Union Bankshares Corporation
 June 24, 2024 Page 2
 FirstName LastName
Robert M. Gorman
Atlantic Union Bankshares Corporation
June 24, 2024
Page 2
2.In addition, we note your disclosure on page 18 that CRE loans also typically have larger
loan balances, and, therefore, the deterioration of one or a few of these loans could cause a
significant increase in the percentage of your non-performing loans. Please revise your
future periodic filings to clarify any specific risk management policies, procedures or
other actions undertaken by management that address the current CRE 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 Katharine Garrett at 202-551-2332 or John Spitz at 202-551-3484 with any
questions.
Sincerely,
Division of Corporation Finance
Office of Finance