Correspondence 0001552781-23-000480 from FIRST COMMUNITY CORP /SC/ (FCCO)
FIRST COMMUNITY CORP /SC/
Date: Dec. 22, 2023 · CIK: 0000932781 · Accession: 0001552781-23-000480
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 000-28344
Referenced dates: December 21, 2023
Letter
United States Securities and Exchange Commission Division of Corporation Finance Re: First Community Corporation Form 10-K for Fiscal Year Ended December 31, 2022 Form 8-K filed October 18, 2023 File No. 000-28344
Dear Messrs. Henderson and Klein,
This letter is being submitted in response to the comment letter dated December 21, 2023 (the “Comment Letter”) from the staff of the Division of Corporation Finance (the “Staff”) of the U.S. Securities and Exchange Commission (the “Commission”) relating to First Community Corporation’s (the “Company’s”) Annual Report on Form 10-K for the fiscal year ended December 31, 2022 and Current Report on Form 8-K furnished to the Commission on October 18, 2023.
For your convenience, the text of the Staff’s comments is set forth in italics followed by the Company’s responses. The headings and numbered responses below correspond to the headings and numbered comments in the Comment Letter.
Form 8-K filed October 18, 2023
Exhibit 99.1
1. We note your response to prior comment 1. Your presentation of tangible common equity per common share excluding accumulated other comprehensive loss and tangible common equity to tangible assets excluding accumulated other comprehensive loss represents individually tailored accounting measures given that the adjustment to exclude accumulated other comprehensive loss has the effect of changing the recognition and measurement principles required to be applied in accordance with GAAP. Therefore, please remove the presentation of these non-GAAP measures from your future filings. Refer to Question 100.04 of the Division of Corporation Finance’s Compliance & Disclosure Interpretations on Non-GAAP Financial Measures and Rule 100(b) of Regulation G.
Response
The Company acknowledges the Staff’s comment and confirms that in future filings, it will remove both (i) tangible common equity per common share excluding accumulated other comprehensive loss and (ii) tangible common equity to tangible assets excluding accumulated other comprehensive loss.
***
If you have any questions regarding this letter, please do not hesitate to contact me at (803) 951-0516.
Sincerely,
First Community Corporation
Show Raw Text
CORRESP 1 filename1.htm First Community Corporation 5455 Sunset Blvd. Lexington, SC 29072 December 22, 2023 United States Securities and Exchange Commission Division of Corporation Finance 100 F Street, N.E. Washington, D.C. 20549 Attn: Michael Henderson and Robert Klein Re: First Community Corporation Form 10-K for Fiscal Year Ended December 31, 2022 Form 8-K filed October 18, 2023 File No. 000-28344 Dear Messrs. Henderson and Klein, This letter is being submitted in response to the comment letter dated December 21, 2023 (the “Comment Letter”) from the staff of the Division of Corporation Finance (the “Staff”) of the U.S. Securities and Exchange Commission (the “Commission”) relating to First Community Corporation’s (the “Company’s”) Annual Report on Form 10-K for the fiscal year ended December 31, 2022 and Current Report on Form 8-K furnished to the Commission on October 18, 2023. For your convenience, the text of the Staff’s comments is set forth in italics followed by the Company’s responses. The headings and numbered responses below correspond to the headings and numbered comments in the Comment Letter. Form 8-K filed October 18, 2023 Exhibit 99.1 1. We note your response to prior comment 1. Your presentation of tangible common equity per common share excluding accumulated other comprehensive loss and tangible common equity to tangible assets excluding accumulated other comprehensive loss represents individually tailored accounting measures given that the adjustment to exclude accumulated other comprehensive loss has the effect of changing the recognition and measurement principles required to be applied in accordance with GAAP. Therefore, please remove the presentation of these non-GAAP measures from your future filings. Refer to Question 100.04 of the Division of Corporation Finance’s Compliance & Disclosure Interpretations on Non-GAAP Financial Measures and Rule 100(b) of Regulation G. Response The Company acknowledges the Staff’s comment and confirms that in future filings, it will remove both (i) tangible common equity per common share excluding accumulated other comprehensive loss and (ii) tangible common equity to tangible assets excluding accumulated other comprehensive loss. *** If you have any questions regarding this letter, please do not hesitate to contact me at (803) 951-0516. Sincerely, First Community Corporation /s/ D. Shawn Jordan D. Shawn Jordan Chief Financial Officer