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SEC Comment Letter for SOUTHERN MISSOURI BANCORP, INC. (SMBC) (CIK 0000916907) (SMBC) — Jul 8, 2011

SOUTHERN MISSOURI BANCORP, INC. (SMBC) (CIK 0000916907)
Date: July 8, 2011 · CIK: 0000916907 · Accession: 0000000000-11-041514

AI Filing Summary & Sentiment

File numbers found in text: 333-174113

Date
July 8, 2011
Author
Not clearly detected
Form
UPLOAD
Company
SOUTHERN MISSOURI BANCORP, INC. (SMBC) (CIK 0000916907)

Letter

UNITED STATES SECURITIES AND EXCHANGE COMMISSION WASHINGTON, D.C. 20549-3561 July 8, 2011 Via E-mail Greg A. Steffens President and Chief Executive Officer Southern Missouri Bancorp, Inc. 531 Vine Street Poplar Bluff, Missouri 63901 Re: Southern Missouri Bancorp, Inc. Registration Statement on Form S-1/A Filed June 27, 2011 File No. 333-174113

Dear Mr. Steffens: We have reviewed your registration statem ent and have the following comments. In some of our comments, we may ask you to provi de us with information so we may better understand your disclosure. Please respond to this letter within te n business days by amending your registration statement and providing the requested inform ation, including a draft of your proposed disclosures to be made in future filings clearly identifying new and deleted disclosure , or by advising us when you will provide the requested response. If you do not believe our comments apply to your facts and circumstances or do not be lieve an amendment is appropriate, please tell us why in your response. After reviewing any amendment to your re gistration statement and the information you provide in response to these comments, we may have additional comments. General

1. Please add a recent development section to th e summary and disclose at a minimum that management believes that there have been no material adverse changes in the results of operation or financial co ndition thru June 30, 2011.

2. We note the red herring language and that the number of shares to be offered has not been included yet. Please confirm that no preliminary distribution has been made.

Mr. Greg A. Steffens Southern Missouri Bancorp, Inc. July 8, 2011 Page 2

March 31, 2011 Form 10-Q Impaired Loans (Collateral Dependent), page 7

3. We note your response to comment 11 in your June 24, 2011 letter. Please revise future filings to describe in more detail how you measure impairment on collateral dependent loans in situations where the economic envir onment has worsened and/ or the real estate market has declined since the last appraisal. Note 4: Loans, page 11

4. We note your response to comments 14 and 15 in your June 24, 2011 lett er. Please revise future filings to clearly disclose that purchas ed credit impaired loans are classified as impaired and on non-accrual status immediat ely after acquisition if they meet the appropriate standards. Additionally, in all of your credit quality disclosures (including disclosures of impaired and non- accrual loans), please clearly disclose if purchased credit impaired loans are included and quantify the amount.

5. Also, please discuss the comparability of your credit metrics and trends between periods and with your peers considering that you have reduced the carrying value of these loans to fair value during purchase accounting a nd therefore these loans which may be classified and reported as non-accrual or im paired may not have any loss content.

6. We note your response to comment 27 in your June 24, 2011 letter. Please note that ASC 310-10-50-15(c)(1), (2) and (3 ) requires information about impaired loans, not non- accrual loans. Please revise futu re filings accordingly.

7. We note your response to comment 28 in your June 24, 2011 letter. Please note that ASC 310-10-50-19 relates to all impaired loans, not just acquired impaired loans. Please revise future fili ngs accordingly.

We urge all persons who are responsible for the accuracy and adequacy of the disclosure in the filing reviewed by the staff to be certain that they have provided all information investors require for an informed decision. Since the comp any and its management are in possession of all facts relating to a company’s disclosure, they are responsible for the acc uracy and adequacy of the disclosures they have made. In connection with responding to our comme nts, please provide, in writing, a statement from the company and each filing person acknowledging that:

Mr. Greg A. Steffens Southern Missouri Bancorp, Inc. July 8, 2011 Page 3

 the company or filing person is responsible for the adequacy and accuracy of the disclosure in the filing;  staff comments or changes to disclosure in response to staff comments do not foreclose the Commission from taking any action with respect to the filing; and  the company or filing person may not assert staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.

In addition, please be advise d that the Division of Enfo rcement has access to all information you provide to the sta ff of the Division of Corporati on Finance in our review of your filing or in response to our comments on your filing. You may contact Michael Vo lley at 202-551-3437 or Amit Pande at 202-551-3423 if you have questions regarding comments on the financ ial statements and related matters. You may contact Jessica Livingston at 202-551-3448 or me at 202-551-3434 with any questions.

Sincerely,
/s/ Michael R. Clampitt M i c h a e l C l a m p i t t Senior Counsel

Show Raw Text
UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-3561

July 8, 2011

Via E-mail
Greg A. Steffens President and Chief Executive Officer Southern Missouri Bancorp, Inc. 531 Vine Street Poplar Bluff, Missouri  63901
 Re: Southern Missouri Bancorp, Inc.
Registration Statement on Form S-1/A
  Filed June 27, 2011   File No. 333-174113

 Dear Mr. Steffens:
We have reviewed your registration statem ent and have the following comments.  In
some of our comments, we may ask you to provi de us with information so we may better
understand your disclosure.
 Please respond to this letter within te n business days by amending your registration
statement and providing the requested inform ation, including a draft of your proposed
disclosures to be made in future filings clearly identifying new and deleted disclosure
, or by
advising us when you will provide the requested response.   If you do not believe our comments
apply to your facts and circumstances or do not be lieve an amendment is appropriate, please tell
us why in your response.
 After reviewing any amendment to your re gistration statement and the information you
provide in response to these comments, we may have additional comments.     General

1. Please add a recent development section to th e summary and disclose at a minimum that
management believes that there have been no material adverse changes in the results of
operation or financial co ndition thru June 30, 2011.

2. We note the red herring language  and that the number of shares to be offered has not
been included yet. Please confirm that no preliminary distribution has been made.

Mr. Greg A. Steffens
Southern Missouri Bancorp, Inc.
July 8, 2011 Page 2

March 31, 2011 Form 10-Q
 Impaired Loans (Collateral Dependent), page 7

3. We note your response to comment 11 in your June 24, 2011 letter.  Please revise future
filings to describe in more detail how you measure impairment on collateral dependent
loans in situations where the economic envir onment has worsened and/ or the real estate
market has declined since the last appraisal.
 Note 4: Loans, page 11

4. We note your response to comments 14 and 15 in  your June 24, 2011 lett er.  Please revise
future filings to clearly disclose that purchas ed credit impaired loans are classified as
impaired and on non-accrual status immediat ely after acquisition if they meet the
appropriate standards.  Additionally, in all of your credit quality disclosures (including
disclosures of impaired and non- accrual loans), please clearly disclose if purchased credit
impaired loans are included and quantify the amount.

5. Also, please discuss the comparability of your credit metrics and trends between periods
and with your peers considering that you have  reduced the carrying value of these loans
to fair value during purchase accounting a nd therefore these loans which may be
classified and reported as non-accrual or im paired may not have any loss content.

6. We note your response to comment 27 in your June 24, 2011 letter.  Please note that ASC
310-10-50-15(c)(1), (2) and (3 ) requires information about impaired loans, not non-
accrual loans.  Please revise futu re filings accordingly.

7. We note your response to comment 28 in your June 24, 2011 letter.  Please note that ASC
310-10-50-19 relates to all impaired loans, not just acquired impaired loans.  Please
revise future fili ngs accordingly.

  We urge all persons who are responsible for the accuracy and adequacy of the disclosure
in the filing reviewed by the staff to be certain that they have provided all information investors
require for an informed decision.  Since the comp any and its management are in possession of all
facts relating to a company’s disclosure, they are responsible for the acc uracy and adequacy of
the disclosures they have made.     In connection with responding to our comme nts, please provide, in writing, a statement
from the company and each filing person acknowledging that:

Mr. Greg A. Steffens
Southern Missouri Bancorp, Inc.
July 8, 2011 Page 3

  the company or filing person is responsible  for the adequacy and accuracy of the
disclosure in the filing;
 staff comments or changes to disclosure in response to staff comments do not foreclose
the Commission from taking any action with respect to the filing; and
 the company or filing person may not assert  staff comments as a defense in any
proceeding initiated by the Commission or any person under the federal securities laws of
the United States.

In addition, please be advise d that the Division of Enfo rcement has access to all
information you provide to the sta ff of the Division of Corporati on Finance in our review of your
filing or in response to our comments on your filing.
 You may contact Michael Vo lley at 202-551-3437 or Amit Pande at 202-551-3423 if you
have questions regarding comments on the financ ial statements and related matters.  You may
contact Jessica Livingston at 202-551-3448 or me at 202-551-3434 with any questions.

Sincerely,
               /s/ Michael R. Clampitt         M i c h a e l  C l a m p i t t          Senior Counsel