SEC Comment Letter for COLUMBIA BANKING SYSTEM, INC. (COLB) (CIK 0000887343) (COLB) — Nov 24, 2009
COLUMBIA BANKING SYSTEM, INC. (COLB) (CIK 0000887343)
Date: Nov. 24, 2009 · CIK: 0000887343 · Accession: 0000000000-09-066779
AI Filing Summary & Sentiment
File numbers found in text: 000-20288
Letter
UNITED STATE SECURITES AND EXCHANGE COMMISSION WASHINGTON. D.C. 20549 P1VISION Of COlOlATION FJ..NCE Mail St(p 4720 Juy 22, 2009 Mr. Ga R. Schinkey Executive Vice Prident and Chief Financial Ofcer Columbia Baning System Inc. 1301 "A" Strt '* Tacoma, Washington 98402 Re: Çnlumbia Banking System, Inc. Form iø. for the FÎleal Year Ended Decenier 31, 2008 Form 1O- for the Period Ended March 31. 200 Form 8-K Filed June is. Z009 File No. 000-20288 De Mr. Schiìney: We have reviewed yt\U response datt May 28, 2009 to our comment lette.r dm Aprî130, 2009 an have the following con'lent$. Wher indicated, we th your documents should be revise. If you disagr, we will consider your explantion as to why our comment are inapplicable or a revision is uncessa. Please be as detaed as necear in your explanation. In your response, plea indicate your Ìlw..-nt to include the requesed revision in fit\Ue fùîngs and provide a dr of your propose disclosure. In some of our comments, we may ask you to provide us with informtion so we may better under your disclosur. After reewing th informaton, we may have additio.na oomments. * * **
.M. Gar R. Schminkey Columbia Bang System, Inc. July 22, 2009 Page 2 00 form 10-K for the Fisc Y ~ EDged Decembe 31, 2008 Item 7. Mangement's Discussion and Anvsis of Financial Condition and Results of Opration Critical Accounting Polici~. Valuation and Recovcrabiltv of Goodwill. Plle 27 1. We note your respnse to pror comment 2 in our lettr dated April 30, 2009. Considcringthe natu and complexity of ths crtiea estimate we believe expaned disclosur would be beneficial to ~ investr. Please revise your futu fiings (sting with xour Form i O-Q for the period ended June 30, 2009) to include disclosur conSisteii with the informaton provided in your corrspondence to us datÑ.ay28, 2009. 2. Considering the severity of the inormation disclosed in your Form 8-K filed June 15,2009 (i.e. compavely high provision), tell us how you consider parh 17 of SF AS 142 when determig 1f additional interi goodwil impairment testing WdS necsar and provide the results of such testi if applicale. See alo our comment above. Financial Condition Loan Portolio. page 38 3 . We note your respons to prior comment 4 in our lett dated April 30, 2009. Additionally. we note your disclosur in the Form 8-K fi1ed June 15, 2009 concerng the provision for loa losss related to previously disclosed nonperforming residetial consction loans. Pleae tell us, and addrss the followig in fue filings concerng impared loas: · in those inst where you determined that a loan was impaire. explain in detl how you deted the fa value of the underlyin collatera. Your response should discss. but not be lìmited to, valuation models and technques us signficant asumptions used, aprasas obtaed (timing, th-par orin-house apprisas, etc.), ote; and · in reds to the preceing point, tell us how .frequently you upda your valuations on yourimpaì loan and the das of you las apprasals andJor internal valuation estimates for mateal impai loans rerded with added emphasis on the loan tht requied a spefic allowace asdiscloscd in the June 15, 2009 8~K.
Mr. Gar R. Schminkey Coliubia Bang System Inc. July 22, 2009 Page 3 of3 Form &-K Filed June 15. 2009 4. We note your presentation of adjusted pre-ta income excludg loan losses and certn items. In our previously issued comment 1 in our lettr dated Apñl30, 2UU9, we referenc the applicabilty ofItem 10 (e)(l) ofRegution S-K andits applicabilty to Item 2.02 Form 8-K. We also note Item 1 OC e)(l )(ií)(B) of Regulaton S-K prohibits using anon-GAA performance meaure to eliminate or smooth items identified as non-reurng, infrUet QC unusua, when the natu of th chare is such tht it is renaly likely to recr with two yeas or ther was a sirilarcharge within the pñor two Yea. Accrdingly, explai how your meae of adjuste preta incoe (parcularly the adjusents excluding the provision for loan losss. interst reverss, and impaents of investment securties) conforms to ths j;resentatìon. Pleas advise or revise to eliminate such adjustments frm ths an fftueñlings. For additional guidce, se Question #8 from the Frequently Asked Questions Regaing the Use ofNon-GAA Financial Meaur, wmchcan be found on th SEC website. .** 'l You may contat Dave Irg, Sta Accountat, at (202) 551-3321, or me at (202) 551-3872 if you any questions. Sincely, Hug West Branch Chief
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UNITED STATE SECURITES AND EXCHANGE COMMISSION WASHINGTON. D.C. 20549 P1VISION Of COlOlATION FJ..NCE Mail St(p 4720 Juy 22, 2009 Mr. Ga R. Schinkey Executive Vice Prident and Chief Financial Ofcer Columbia Baning System Inc. 1301 "A" Strt '* Tacoma, Washington 98402 Re: Çnlumbia Banking System, Inc. Form iø. for the FÎleal Year Ended Decenier 31, 2008 Form 1O- for the Period Ended March 31. 200 Form 8-K Filed June is. Z009 File No. 000-20288 De Mr. Schiìney: We have reviewed yt\U response datt May 28, 2009 to our comment lette.r dm Aprî130, 2009 an have the following con'lent$. Wher indicated, we th your documents should be revise. If you disagr, we will consider your explantion as to why our comment are inapplicable or a revision is uncessa. Please be as detaed as necear in your explanation. In your response, plea indicate your Ìlw..-nt to include the requesed revision in fit\Ue fùîngs and provide a dr of your propose disclosure. In some of our comments, we may ask you to provide us with informtion so we may better under your disclosur. After reewing th informaton, we may have additio.na oomments. * * ** .M. Gar R. Schminkey Columbia Bang System, Inc. July 22, 2009 Page 2 00 form 10-K for the Fisc Y ~ EDged Decembe 31, 2008 Item 7. Mangement's Discussion and Anvsis of Financial Condition and Results of Opration Critical Accounting Polici~. Valuation and Recovcrabiltv of Goodwill. Plle 27 1. We note your respnse to pror comment 2 in our lettr dated April 30, 2009. Considcringthe natu and complexity of ths crtiea estimate we believe expaned disclosur would be beneficial to ~ investr. Please revise your futu fiings (sting with xour Form i O-Q for the period ended June 30, 2009) to include disclosur conSisteii with the informaton provided in your corrspondence to us datÑ.ay28, 2009. 2. Considering the severity of the inormation disclosed in your Form 8-K filed June 15,2009 (i.e. compavely high provision), tell us how you consider parh 17 of SF AS 142 when determig 1f additional interi goodwil impairment testing WdS necsar and provide the results of such testi if applicale. See alo our comment above. Financial Condition Loan Portolio. page 38 3 . We note your respons to prior comment 4 in our lett dated April 30, 2009. Additionally. we note your disclosur in the Form 8-K fi1ed June 15, 2009 concerng the provision for loa losss related to previously disclosed nonperforming residetial consction loans. Pleae tell us, and addrss the followig in fue filings concerng impared loas: · in those inst where you determined that a loan was impaire. explain in detl how you deted the fa value of the underlyin collatera. Your response should discss. but not be lìmited to, valuation models and technques us signficant asumptions used, aprasas obtaed (timing, th-par orin-house apprisas, etc.), ote; and · in reds to the preceing point, tell us how .frequently you upda your valuations on yourimpaì loan and the das of you las apprasals andJor internal valuation estimates for mateal impai loans rerded with added emphasis on the loan tht requied a spefic allowace asdiscloscd in the June 15, 2009 8~K. 2 Mr. Gar R. Schminkey Coliubia Bang System Inc. July 22, 2009 Page 3 of3 Form &-K Filed June 15. 2009 4. We note your presentation of adjusted pre-ta income excludg loan losses and certn items. In our previously issued comment 1 in our lettr dated Apñl30, 2UU9, we referenc the applicabilty ofItem 10 (e)(l) ofRegution S-K andits applicabilty to Item 2.02 Form 8-K. We also note Item 1 OC e)(l )(ií)(B) of Regulaton S-K prohibits using anon-GAA performance meaure to eliminate or smooth items identified as non-reurng, infrUet QC unusua, when the natu of th chare is such tht it is renaly likely to recr with two yeas or ther was a sirilarcharge within the pñor two Yea. Accrdingly, explai how your meae of adjuste preta incoe (parcularly the adjusents excluding the provision for loan losss. interst reverss, and impaents of investment securties) conforms to ths j;resentatìon. Pleas advise or revise to eliminate such adjustments frm ths an fftueñlings. For additional guidce, se Question #8 from the Frequently Asked Questions Regaing the Use ofNon-GAA Financial Meaur, wmchcan be found on th SEC website. .** 'l You may contat Dave Irg, Sta Accountat, at (202) 551-3321, or me at (202) 551-3872 if you any questions. Sincely, Hug West Branch Chief