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SEC Company Response from FIRST COMMUNITY — Jul 25, 2005

FIRST COMMUNITY CORP /TN/ (CIK 0000924960)
Date: July 25, 2005 · CIK: 0000924960 · Accession: 0000950144-05-007669

AI Filing Summary & Sentiment

Referenced dates: July 14, 2005

Date
July 25, 2005
Author
By
Form
CORRESP
Company
FIRST COMMUNITY CORP /TN/ (CIK 0000924960)

Letter

VIA EDGAR AND OVERNIGHT COURIER Division of Corporation Finance United States Securities and Exchange Commission Filed March 31, 2005 Form 10-QSB for Fiscal Quarter Ended March 31, 2005 Filed May 16, 2005 Commission’s File No. 0-25972

Dear Mr. Ohsiek,

First Community Corporation acknowledges receipt of your letter dated July 14, 2005, and we are filing today via EDGAR an amended annual report for the fiscal year ending December 31, 2004, on Form 10-KSB/A to amend the company’s annual report originally filed on March 31, 2005, to conform to the request in your letter. We have addressed your comments with additional detail below.

Form 10-KSB for Fiscal Year Ended December 31, 2004

Report of Independent Registered Public Accounting Firm, page F-1

In response to the Staff’s comments, we have discussed the Staff’s request with Crowe Chizek and Company LLC, the independent registered public accounting firm who delivered the report, and have obtained from that firm a revised report that refers to “the standards of the Public Company Accounting Oversight Board (United States)” in accord with PCAOB Auditing Standard No. 1. The amended annual report we are filing today amends Item 7 in order to re-file the revised report of Crowe Chizek and Company LLC as you requested. Enclosed with the overnight package is a signed copy of the

Mr. George Ohsiek

July 25, 2005

Page 2

revised report from Crowe Chizek and Company LLC for your reference and a copy of the amended annual report on Form 10-KSB/A as filed via EDGAR.

In your letter you also asked that the following be acknowledged on behalf of First Community Corporation in connection with the response to the Commission Staff’s comments:

1.

First Community Corporation acknowledges that the company is responsible for the adequacy and accuracy of the disclosure in the filing;

2.

Commission Staff comments or changes to disclosures by First Community Corporation in response to Staff comments do not foreclose the Commission from any action with respect to the filing; and

3.

First Community Corporation may not assert Commission Staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.

Should you have any questions regarding this filing, please do not hesitate to contact the undersigned, or our counsel in Nashville, Trace Blankenship, at Bone McAllester Norton PLLC (615/238-6331).

Sincerely,
FIRST COMMUNITY CORPORATION

Show Raw Text
CORRESP
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Corresp to SEC

FIRST COMMUNITY CORPORATION

809 WEST MAIN STREET

P.O. BOX 820

ROGERSVILLE, TENNESSEE 37857

Telephone: (423) 272-5800

Facsimile: (423) 272-1962

July 25, 2005

VIA EDGAR AND OVERNIGHT COURIER

Mr. George Ohsiek

Branch Chief

Division of Corporation Finance

United States Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549-3561

    Re:

    First Community Corporation

    Form 10-KSB for Fiscal Year Ending December 31, 2004

    Filed March 31, 2005

    Form 10-QSB for Fiscal Quarter Ended March 31, 2005

    Filed May 16, 2005

    Commission’s File No. 0-25972

Dear Mr. Ohsiek,

     First Community Corporation acknowledges receipt of your letter dated July 14, 2005, and we
are filing today via EDGAR an amended annual report for the fiscal year ending December 31, 2004,
on Form 10-KSB/A to amend the company’s annual report originally filed on March 31, 2005, to
conform to the request in your letter. We have addressed your comments with additional detail
below.

     Form 10-KSB for Fiscal Year Ended December 31, 2004

     Report of Independent Registered Public Accounting Firm, page F-1

      In response to the Staff’s comments, we have discussed the Staff’s request with Crowe
Chizek and Company LLC, the independent registered public accounting firm who delivered the
report, and have obtained from that firm a revised report that refers to “the standards of
the Public Company Accounting Oversight Board (United States)” in accord with PCAOB Auditing
Standard No. 1. The amended annual report we are filing today amends Item 7 in order to
re-file the revised report of Crowe Chizek and Company LLC as you requested. Enclosed with
the overnight package is a signed copy of the

Mr. George Ohsiek

July 25, 2005

Page 2

revised report from Crowe Chizek and Company LLC for your reference and a copy of the
amended annual report on Form 10-KSB/A as filed via EDGAR.

     In your letter you also asked that the following be acknowledged on behalf of First Community
Corporation in connection with the response to the Commission Staff’s comments:

    1.

    First Community Corporation acknowledges that the company is responsible for
the adequacy and accuracy of the disclosure in the filing;

    2.

    Commission Staff comments or changes to disclosures by First Community
Corporation in response to Staff comments do not foreclose the Commission from any
action with respect to the filing; and

    3.

    First Community Corporation may not assert Commission Staff comments as a
defense in any proceeding initiated by the Commission or any person under the federal
securities laws of the United States.

     Should you have any questions regarding this filing, please do not hesitate to contact the
undersigned, or our counsel in Nashville, Trace Blankenship, at Bone McAllester Norton PLLC
(615/238-6331).

    Sincerely,

    FIRST COMMUNITY CORPORATION

    By:

    /s/ Mark A. Gamble

    Mark A. Gamble

    President

Enclosures (2)

    Copy:

    Sarah Goldberg, Securities and Exchange Commission (with enclosures)

    Trace Blankenship, Bone McAllester Norton, PLLC (with enclosures)

    Jack F. Stringham, Bone McAllester Norton, PLLC (with enclosures)