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SEC Comment Letter for HOPFED BANCORP INC (CIK 0001041550) — Aug 26, 2005

HOPFED BANCORP INC (CIK 0001041550)
Date: Aug. 26, 2005 · CIK: 0001041550 · Accession: 0000000000-05-044342

AI Filing Summary & Sentiment

File numbers found in text: 000-23667

Date
August 26, 2005
Author
John P. Nolan
Form
UPLOAD
Company
HOPFED BANCORP INC (CIK 0001041550)

Letter

Mail Stop 4561 August 26, 2005 Mr. John E. Peck Chief Executive Officer Hopfed Bancorp, Inc. 2700 Fort Campbell Boulevard Hopkinsville, KY 42240

Re: Hopfed Bancorp, Inc. Form 10-K for the Fiscal Year Ended December 31, 2004 Forms 10-Q for the Fiscal Quarters Ended March 31, 2005 and June 30, 2005 File Number: 000-23667

Dear Mr. Peck:

We have reviewed your filings and have the following comment. Where indicated, we think you should revise your document in response to this comment. If you disagree, we will consider your explanation as to why our comment is inapplicable or a revision is unnecessary. Please be as detailed as necessary in your explanation. In our comment, we may ask you to provide us with supplemental information so we may better understand your disclosure. After reviewing this information, we may or may not raise additional 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 on March 31, 2005

Notes to Consolidated Financial Statements

Note 1. Summary of Significant Accounting Policies

Loans Receivable, page F-11

1. We note your accounting policy that states that loan origination fee income is recognized as received and direct loan origination costs are expensed as incurred, which is not in accordance with GAAP, specifically paragraphs 5-7 of SFAS No. 91. You also state that the deferral of such fees and costs would not have a material effect on the consolidated financial statements. Please provide to us quantitative and qualitative support for which you were able to base your conclusion for all periods presented in your filing. We may have further comment upon receipt and review of your response.

As appropriate, please amend your filing and respond to these comments within 10 business days or tell us when you will provide us with a response. You may wish to provide us with marked copies of the amendment to expedite our review. Please furnish a cover letter with your amendment that keys your responses to our comments and provides any requested supplemental information. Detailed cover letters greatly facilitate our review. Please understand that we may have additional comments after reviewing your amendment and responses to our comments.

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 John Spitz at (202) 551-3484 or me at (202) 551-3492 if you have questions.

Sincerely,
John P. Nolan
Accounting Branch Chief

Show Raw Text
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<TEXT>

Mail Stop 4561
                                                August 26, 2005

Mr. John E. Peck
Chief Executive Officer
Hopfed Bancorp, Inc.
2700 Fort Campbell Boulevard
Hopkinsville, KY 42240

Re:	Hopfed Bancorp, Inc.
	Form 10-K for the Fiscal Year Ended December 31, 2004
	Forms 10-Q for the Fiscal Quarters Ended
      March 31, 2005 and June 30, 2005
	File Number: 000-23667

Dear Mr. Peck:

      We have reviewed your filings and have the following
comment.
Where indicated, we think you should revise your document in
response
to this comment.  If you disagree, we will consider your
explanation
as to why our comment is inapplicable or a revision is
unnecessary.
Please be as detailed as necessary in your explanation.  In our
comment, we may ask you to provide us with supplemental
information
so we may better understand your disclosure.  After reviewing this
information, we may or may not raise additional 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 on March 31, 2005

Notes to Consolidated Financial Statements

Note 1. Summary of Significant Accounting Policies

Loans Receivable, page F-11

1. We note your accounting policy that states that loan
origination
fee income is recognized as received and direct loan origination
costs are expensed as incurred, which is not in accordance with
GAAP,
specifically paragraphs 5-7 of SFAS No. 91. You also state that
the
deferral of such fees and costs would not have a material effect
on
the consolidated financial statements. Please provide to us
quantitative and qualitative support for which you were able to
base
your conclusion for all periods presented in your filing. We may
have
further comment upon receipt and review of your response.

       As appropriate, please amend your filing and respond to
these
comments within 10 business days or tell us when you will provide
us
with a response.  You may wish to provide us with marked copies of
the amendment to expedite our review.  Please furnish a cover
letter
with your amendment that keys your responses to our comments and
provides any requested supplemental information.  Detailed cover
letters greatly facilitate our review.  Please understand that we
may
have additional comments after reviewing your amendment and
responses
to our comments.

	 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 John Spitz at (202) 551-3484 or me at (202)
551-3492 if you have questions.

      Sincerely,

      John P. Nolan
      Accounting Branch Chief

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Mr. John E. Peck
Hopfed Bancorp, Inc.
August 26, 2005
Page 1

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