SEC Comment Letter 0000000000-23-008056 to QCR HOLDINGS INC (QCRH) (CIK 0000906465) (QCRH)
QCR HOLDINGS INC (QCRH) (CIK 0000906465)
Date: July 27, 2023 · CIK: 0000906465 · Accession: 0000000000-23-008056
AI Filing Summary & Sentiment
File numbers found in text: 000-22208
Letter
United States securities and exchange commission logo July 27, 2023 Larry J. Helling Chief Executive Officer QCR Holdings, Inc. 3551 7th Street Moline, IL 61265 Re:QCR Holdings, Inc. Definitive Proxy Statement on Schedule 14A Filed April 4, 2023 File No. 000-22208 Dear Larry J. Helling: We have limited our review of your most recent definitive proxy statement to those issues we have addressed in our comments. Please respond to these comments by confirming that you will revise your future proxy disclosures in accordance with the topics discussed below. Definitive Proxy Statement on Schedule 14A filed April 4, 2023 Pay Versus Performance, page 47 1.We note that you included Adjusted Earnings Per Share, a non-GAAP measure, as your Company-Selected Measure pursuant to Regulation S-K Item 402(v)(2)(vi). Please ensure that you provide disclosure showing how this number is calculated from your audited financial statements, as required by Regulation S-K Item 402(v)(2)(v). 2.Please ensure that the reconciliation table at the top of page 48 shows each of the numerical amounts added under Regulation S-K Item 402(v)(2)(iii)(B)(1)(i) and (ii) to calculate the "Pension Benefit Adjustments." See Regulation S-K Item 402(v)(3). For guidance, refer to Regulation S-K Compliance and Disclosure Interpretations Question 128D.04.
FirstName LastNameLarry J. Helling Comapany NameQCR Holdings, Inc. July 27, 2023 Page 2 FirstName LastName Larry J. Helling QCR Holdings, Inc. July 27, 2023 Page 2 Please contact John Stickel at 202-551-3324 or Charlie Guidry at 202-551-3621 with any questions. Sincerely, Division of Corporation Finance Disclosure Review Program
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United States securities and exchange commission logo
July 27, 2023
Larry J. Helling
Chief Executive Officer
QCR Holdings, Inc.
3551 7th Street
Moline, IL 61265
Re:QCR Holdings, Inc.
Definitive Proxy Statement on Schedule 14A
Filed April 4, 2023
File No. 000-22208
Dear Larry J. Helling:
We have limited our review of your most recent definitive proxy statement to those issues
we have addressed in our comments. Please respond to these comments by confirming that you
will revise your future proxy disclosures in accordance with the topics discussed below.
Definitive Proxy Statement on Schedule 14A filed April 4, 2023
Pay Versus Performance, page 47
1.We note that you included Adjusted Earnings Per Share, a non-GAAP measure, as your
Company-Selected Measure pursuant to Regulation S-K Item 402(v)(2)(vi). Please ensure
that you provide disclosure showing how this number is calculated from your audited
financial statements, as required by Regulation S-K Item 402(v)(2)(v).
2.Please ensure that the reconciliation table at the top of page 48 shows each of the
numerical amounts added under Regulation S-K Item 402(v)(2)(iii)(B)(1)(i) and (ii) to
calculate the "Pension Benefit Adjustments." See Regulation S-K Item 402(v)(3). For
guidance, refer to Regulation S-K Compliance and Disclosure Interpretations
Question 128D.04.
FirstName LastNameLarry J. Helling
Comapany NameQCR Holdings, Inc.
July 27, 2023 Page 2
FirstName LastName
Larry J. Helling
QCR Holdings, Inc.
July 27, 2023
Page 2
Please contact John Stickel at 202-551-3324 or Charlie Guidry at 202-551-3621 with any
questions.
Sincerely,
Division of Corporation Finance
Disclosure Review Program