SEC Comment Letter for GS FINANCIAL CORP (CIK 0001029630) — Sep 22, 2005
GS FINANCIAL CORP (CIK 0001029630)
Date: Sept. 22, 2005 · CIK: 0001029630 · Accession: 0000000000-05-049182
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May 24, 2005
Mail Stop 4561
By U.S. Mail and facsimile to (504) 457-6227
Ralph E. Weber
President & Chief Executive Officer
GS Financial Corp.
3798 Veterans Boulevard
Metairie, LA 70002
Re: GS Financial Corp.
Form 10-K for the year ended December 31, 2004
File No. 0-22269
Dear Mr. Weber:
We have reviewed your filing and have the following comment.
We have limited our review to the matter related to the issue
raised
in our comment. In our comment, we have asked you to provide us
with
additional information so we may better understand your
disclosure.
After reviewing this information, we may or may not raise
additional
comments. Please be as detailed as necessary in your explanation.
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 comment or any other aspect
of
our review. Feel free to call us at the telephone numbers listed
at
the end of this letter.
2004 Annual Report
Item 8 - Financial Statements and Supplementary Data
Note B - Securities - Available-for-Sale
1. In light of the significant other-than-temporary impairments
charges recorded by other holders of FHLMC preferred shares and
considering the market conditions surrounding those shares, please
advise us of the following:
* The nature of the loss on available-for-sale securities
reflected
in the income statement;
* The nature of unrealized losses in available-for-sale securities
reflected in other comprehensive income in 2004 and 2003;
* The nature of the loss on write-down of available-for-sale
securities reflected in the statement of cash flows in 2004;
* The reasons for the change in the investment in FHLMC preferred
shares between 2004 and 2003; and
* Provide any additional commentary in support of the fact that
your
FHLMC preferred shares were not impaired at 12/31/03 and 12/31/04.
* * * *
Please respond to this comment within 10 business days or
tell
us when you will provide us with a response. Please furnish a
letter
that keys your responses to our comment. Please file your
response
letter on EDGAR. Please understand that we may have additional
comments after reviewing your response to our comment.
We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filing reviewed by the staff to
be
certain that they have provided all information investors require
for
an informed 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 Isa Farhat at (202) 551-3485 or me at (202)
551-3851 if you have questions regarding comments on the financial
statements and related matters.
Sincerely,
Paul Cline
Senior Accountant
Ralph E. Weber
GS Financial Corp.
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