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
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<TYPE>LETTER
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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
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