SEC Company Response from FNB CORP \VA\ (CIK 0001010961) — Aug 1, 2005
FNB CORP \VA\ (CIK 0001010961)
Date: Aug. 1, 2005 · CIK: 0001010961 · Accession: 0001010961-05-000101
AI Filing Summary & Sentiment
File numbers found in text: 000-24141
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<TYPE>CORRESP
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<FILENAME>filename1.txt
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July 29, 2005
By: EDGAR and U. S. Mail
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:
This letter is in response to your follow-up letter of July 1, 2005
regarding our Form 10-K for the year ended December 31, 2004.
In our letter to you dated June 27, 2005, we reported that the fees
included in loan income were $1,459,000, $1,584,000 and $944,000 for the
years ended December 31, 2004, 2003 and 2002, respectively. FNB Corporation
acquired Bedford Federal Saving Bank in August, 2003. In our earlier
response, the 2003 fees were overstated as an extra quarter of Bedford's fees
was included when our analysis was prepared. The correct amounts were
$1,459,000, $1,181,000 and $944,000 for the years December 31, 2004, 2003 and
2002, respectively. We apologize for any inconvenience this incorrect
information may have created.
Due to the nature of our loan portfolios, the impact of the use of a
level yield method should not produce significantly different results from
straight line as the longest term loans are approximately 25% of the
portfolio and neither the activity in these portfolios nor our fee schedule
has changed significantly during the periods. The balance of loan fees is
related to loans of short term and duration, such as construction loans, or
lines of credit for which use of the straight-line method is appropriate.
Empirically we recognize that without significant change in lending
activities or the fee schedules of the Company, recognition of deferred net
fees on the straight-line basis versus the level yield method should not have
a material impact on net income over term.
We evaluate the impact on net income by computing fee income on
amortizing loans using the sum-of-the-years digits method over both estimated
portfolio duration and average weighted portfolio maturities which
approximates the level yield method. This evaluation is completed on each
applicable portfolio of loans by subsidiary, except for lines of credit and
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United States Securities and Exchange Commission
Page 2
July 29, 2005
an adjustable rate mortgage product with a first year "introductory rate."
In order to respond to your inquiry, we updated our testing through December
31, 2004. In the following table we have summarized the difference in fee
income on loans included in our December 31, 2004, Form 10-K and that
calculated in our testing.
2004 2003 2002
Fees as reported $ 1,459,000 $ 1,181,000 $ 944,000
Using duration analysis
Fees per our test 1,414,570 1,230,186 997,505
Net difference 44,430 (49,186) (53,505)
Using weighted average
maturity
Fees per our test 1,483,037 1,227,730 860,406
Net difference (24,037) (46,730) 83,594
Total interest and
fees on loans 61,911,000 52,712,000 49,285,000
Net income before
income tax 22,274,000 19,346,000 16,316,000
Difference as a percentage
of total interest and
fees on loans 0.07% to -0.04% -0.09% to -0.09% -0.11% to 0.17%
Difference as a percentage
of net income before
income tax 0.20% to -0.11% -0.25% to -0.24% -0.33% to 0.51%
We think the impact on our income statement and balance sheet of using
the straight-line method of amortization for certain net loan fees is not
material as the differences reflected above could not reasonably influence a
reader's conclusions about our financial condition, results of operations or
cash flows.
We appreciate that you allowed us to delay response to your July 1,
2005, letter until the end of the month and hope the above information
satisfactorily responds to your question. 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. 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
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