SEC Company Response from FNB CORP \VA\ (CIK 0001010961) — Jul 1, 2005
FNB CORP \VA\ (CIK 0001010961)
Date: July 1, 2005 · CIK: 0001010961 · Accession: 0001010961-05-000097
AI Filing Summary & Sentiment
File numbers found in text: 000-24141
Show Raw Text
<DOCUMENT>
<TYPE>CORRESP
<SEQUENCE>1
<FILENAME>filename1.txt
<TEXT>
June 27, 2005
By: U.S. Mail and facsimile to (202) 772-9208
Mr. John P. Nolan, Accounting Branch Chief and
Ms. Lisa Haynes, Staff Accountant
United States Securities and Exchange Commission
Washington, D.C. 20549
RE: FNB Corporation
Form 10-K
File No. 000-24141
Dear Mr. Nolan and Ms. Haynes:
Included in the paragraphs which follow are responses to the four
questions raised in your letter of June 16, 2005 related to our Form 10-K for
the year ended December 31, 2004. To facilitate your review, we have
presented our responses in the same order and under the same captions used in
your letter.
Management's Discussion and Analysis of Financial Condition and Results of
Operations - Noninterest income, page 6
Comment 1.
As discussed in Footnote 1 (e), in accordance with FASB 91, loan
origination and commitment fees and certain costs are deferred, and the net
amount is amortized over the contractual life of the related loans as an
adjustment of the yield. These fees were $1,459,000, $1,584,000 and $944,000
for the years ended December 31, 2004, 2003 and 2002, respectively, and are
included in the caption "Interest income: Interest and fees on loans" in the
Statement of Income. Fees were higher in 2004 and 2003 due to the
acquisition of Bedford Federal Savings Bank on August 1, 2003. These fees
were 2.36%, 3.01% and 1.92% of total income from loans in 2004, 2003 and
2002, respectively. The net fees are amortized into income on the straight-
line basis.
Securities and Exchange Commission
Page 2 of 3
June 27, 2005
Comment 2.
The volatility in Loan Origination Fees included in Noninterest income
was related entirely to the volume of secondary mortgage activity. The
volume of transactions was disclosed in Footnote 17 and is presented below.
These fees were $3,131,000, $6,116,000 and $2,894,000 for the years ended
December 31, 2004, 2003 and 2002, respectively. Reflected as a percentage of
loans sold in the secondary market, the fees were 1.33%, 1.35% and 1.34% for
2004, 2003 and 2002, respectively.
Year Ended Loans Originated Loans Sold
December 31 (000's) (000's)
2004 $240,731 $236,048
2003 422,699 452,481
2002 236,300 215,955
There were no changes in the method of accounting for origination fees on
portfolio loans or on those related to secondary market activity during the
periods.
Contractual Cash Obligations, page 10
Comment 3.
It is currently our plan to repay maturities of FHLB Advances by
replacement borrowings from the FHLB. At December 31, 2004, our total
availability under these lines totaled $272,380,000, including outstandings.
During the past three years, proceeds from calls and maturities of securities
have averaged $86,725,000 providing additional funds for repayment if
necessary. Third, reduction in lending activities in relationship to deposit
growth could also provide additional funding.
Comment 4.
Total FHLB borrowings with stated maturities in 2005 were $33 million at
December 31, 2004 as presented in Footnote 10. Total FHLB borrowings with
either stated maturities or call options in 2005 total $52 million at
December 31, 2004 as presented in the Contractual Cash Obligations table
required by Section 229.303 of Regulation S-K. In future filings we will
include an explanatory comment to that effect as a footnote to the table.
Securities and Exchange Commission
Page 3 of 3
June 27, 2005
In accordance with your request, we acknowledge that:
FNB Corporation is responsible for the adequacy and accuracy of the
disclosure in filings with the Securities and Exchange Commission
("Commission");
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
FNB Corporation 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.
We hope these answers satisfactorily resolve the questions raised during
your review of our filing. However, if you desire additional information, if
we need to take further action or we can be of help in any other way, please
let us know. For future reference, the facsimile number for our corporate
offices is 540-381-6768. Thank you for your assistance.
Sincerely yours,
s/William P. Heath, Jr.
William P. Heath, Jr.
President and Chief Executive Officer
s/Daniel A. Becker
Daniel A. Becker
Executive Vice President and Chief
Financial Officer
</TEXT>
</DOCUMENT>