SEC Comment Letter for FNB CORP \VA\ (CIK 0001010961) — Jun 20, 2005
FNB CORP \VA\ (CIK 0001010961)
Date: June 20, 2005 · CIK: 0001010961 · Accession: 0000000000-05-031000
AI Filing Summary & Sentiment
File numbers found in text: 000-24141
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<FILENAME>filename1.txt
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Mail Stop 4561
June 16, 2005
By U.S. Mail and facsimile to (540) 394-6894
William P. Heath, Jr.
President and Chief Executive Officer
FNB Corporation
105 Arbor Drive
Christiansburg, VA 24073
Re: FNB Corporation
Form 10-K
Filed March 15, 2005
File No. 000-24141
Dear Mr. Heath:
We have reviewed your filing and have the following
comments.
In some of our comments, we may ask you to provide us with
information so we may better understand your disclosure. After
reviewing this information, we may raise additional comments. We
have limited our review of your filing to those issues we have
addressed in our comments.
Please understand that the purpose of our review process is
to
assist you in your compliance with the applicable disclosure
requirements and to enhance the overall disclosure in your filing.
We look forward to working with you in these respects. We welcome
any questions you may have about our comments or any other aspect
of
our review. Feel free to call us at the telephone numbers listed
at
the end of this letter.
* * * * * * *
Form 10-K filed March 15, 2005
2004 Annual Report
Management`s Discussion and Analysis of Financial Condition and
Results of Operations
Noninterest income, page 6
1. We note your accounting policy disclosure in Note 1(e) of your
audited financial statements that loan origination fees are
deferred
and amortized over the contractual life of the related loans as an
adjustment of the yield. Please confirm by telling us whether you
follow the guidance in paragraphs 5-7 of SFAS No. 91 or explain
the
method you use to amortize your loan origination fees.
2. As a related matter, please quantify your loans originations
during each period presented and more clearly describe how
fluctuations in originations impacted your origination fee income
for
each period presented in your response letter. Please tell us
whether you changed your method of amortizing origination fee
income
during the periods presented and if so, quantify the financial
statement impact.
Contractual Cash Obligations, page 10
3. We note that your cash and due from banks amounted to
approximately $38 million while cash flow from operations for 2004
were approximately $14 million. In light of these amounts, please
tell us how management intends to fulfill its obligations to repay
FHLB borrowings of $52 million upon maturity in 2005.
4. Please also explain the differences between FHLB borrowings of
$52
million due in less than one year (as disclosed on page 11 of your
annual report) and the $33 million in FHLB advances due in 2005
(as
disclosed in note 10 of your financial statements). We are unable
to
reconcile these amounts.
* * * * * * *
Please respond to these comments within 10 business days or
tell us when you will provide us with a response. Please furnish
a
cover letter with your amendment that keys your responses to our
comments and provides any requested information. Detailed cover
letters greatly facilitate our review. Please understand that we
may
have additional comments after reviewing your responses to our
comments.
We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filing to be certain that the
filing includes all information required under the Securities
Exchange Act of 1934 and that they have provided all information
investors require for an informed investment decision. Since the
company and its management are in possession of all facts relating
to
a company`s disclosure, they are responsible for the accuracy and
adequacy of the disclosures they have made.
In connection with responding to our comments, please
provide,
in writing, a statement from the company acknowledging that:
* the company 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 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 advised that the Division of
Enforcement
has access to all information you provide to the staff of the
Division of Corporation Finance in our review of your filing or in
response to our comments on your filing.
You may contact Lisa Haynes, Staff Accountant, at (202) 551-
3424
or me at (202) 551-3492 if you have questions.
Sincerely,
John P. Nolan
Accounting Branch Chief
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William P. Heath, Jr.
FNB Corporation
June 16, 2005
Page 3
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