Correspondence 0001171843-23-005206 from QCR HOLDINGS INC (QCRH) (CIK 0000906465) (QCRH)
QCR HOLDINGS INC (QCRH) (CIK 0000906465)
Date: Aug. 10, 2023 · CIK: 0000906465 · Accession: 0001171843-23-005206
AI Filing Summary & Sentiment
File numbers found in text: 000-22208
Referenced dates: July 27, 2023
Letter
VIA EDGAR Division of Corporation Finance Attention: John Stickel and Charlie Guidry Re: QCR Holdings, Inc. Definitive Proxy Statement on Schedule 14A Filed April 4, 2023 File No. 000-22208
Dear Mr. Stickel and Mr. Guidry:
QCR Holdings, Inc. (the “Company”) is in receipt of a letter dated July 27, 2023 (the “Comment Letter”) from the staff of the Securities and Exchange Commission (the “Staff”) concerning the above-captioned filing of the Company.
In accordance with the Staff’s Comment Letter, the Company represents as follows:
1. In its discussion of Pay Versus Performance on page 47 in the above-captioned filing, the Company included Adjusted Earnings Per Share, a non-GAAP measure, as its Company-Selected Measure pursuant to Regulation S-K Item 402(v)(2)(vi). The Company will revise its future proxy disclosures to show how this number is calculated from its audited financial statements as required by Regulation S-K Item 402(v)(2)(vi).
2. The Company will further revise its future proxy disclosures to ensure that the reconciliation table on page 48 in the above-captioned filing, 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” as required by Regulation S-K Item 402(v)(3).
The Company believes the foregoing provides a complete response to the Staff’s Comment Letter.
Thank you for your time and feedback on the Company’s disclosures. If you have questions regarding the foregoing or require any additional information, please feel free to contact me directly at (309) 743-7745 or tgipple@qcrh.com.
Sincerely,
/s/ Todd A. Gipple
Show Raw Text
CORRESP
1
filename1.htm
August 10, 2023
VIA EDGAR
Division of Corporation Finance
Disclosure Review Program
U.S. Securities and Exchange Commission
100 F Street, NE
Washington, D.C. 20549
Attention: John Stickel and Charlie Guidry
Re: QCR Holdings, Inc.
Definitive Proxy Statement on Schedule 14A
Filed April 4, 2023
File No. 000-22208
Dear Mr. Stickel and Mr. Guidry:
QCR Holdings, Inc. (the “Company”) is in receipt of a letter
dated July 27, 2023 (the “Comment Letter”) from the staff of the Securities and Exchange Commission (the “Staff”)
concerning the above-captioned filing of the Company.
In accordance with the Staff’s Comment Letter, the Company represents
as follows:
1. In its discussion of Pay Versus Performance on page 47 in the above-captioned filing, the Company included Adjusted Earnings Per Share,
a non-GAAP measure, as its Company-Selected Measure pursuant to Regulation S-K Item 402(v)(2)(vi). The Company will revise its future
proxy disclosures to show how this number is calculated from its audited financial statements as required by Regulation S-K Item 402(v)(2)(vi).
2. The Company will further revise its future proxy disclosures to ensure that the reconciliation table on page 48 in the above-captioned
filing, 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” as required by Regulation S-K Item 402(v)(3).
The Company believes the foregoing provides a complete response to
the Staff’s Comment Letter.
Thank you for your time and feedback on the Company’s disclosures.
If you have questions regarding the foregoing or require any additional information, please feel free to contact me directly at (309)
743-7745 or tgipple@qcrh.com.
Sincerely,
/s/ Todd A. Gipple
Todd A. Gipple
President & Chief Financial Officer
QCR Holdings, Inc.
2