SEC Comment Letter for PEAPACK GLADSTONE FINANCIAL CORP (PGC) (CIK 0001050743) (PGC) — Nov 28, 2006
PEAPACK GLADSTONE FINANCIAL CORP (PGC) (CIK 0001050743)
Date: Nov. 28, 2006 · CIK: 0001050743 · Accession: 0000000000-06-058076
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 001-16197
Letter
Mail Stop 3720 November 15, 2006 Mr. Arthur F. Birmingham Executive Vice President and Chief Financial Officer Peapack-Gladstone Financial Corporation 158 Rout 206 Peapack-Gladstone, NJ 07934
Re: Peapack-Gladstone Financial Corporation Item 4.01 Form 8-K Filed November 15, 2006 File No. 001-16197
Dear Mr. Birmingham:
We have reviewed your filing and have the following comments. Where indicated, we think you should re vise your document in response to these comments. If you disagree, we will consider your explanation as to why our comment is inapplicable or a revision is unnecessary. Please be as deta iled as necessary in your explanation. In some of our comments, we may ask you to provi de us with more information so we may better understand your disclosure. After re viewing this information, we may raise additional comments.
Please understand that the purpose of our re view 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. 1. Please file a revised Form 8-K upon the co mpletion of the audit of the company’s consolidated financial statements as of and for the year ended December 31, 2006, as discussed in Item 4.01 of your Form 8-K filed on November 14, 2006, to include the date upon which the dismissal of your auditors is effective. Please note that all portions of the Form 8- K should be updated, including the section regarding any disagreements. A new E xhibit 16 letter will also be required.
2. Please revise your disclosure to specif ically state whether there were any disagreements, as described in Item 304( a)(1)(iv) of Regulat ion S-K, during the
Mr. Arthur F. Birmingham Peapack-Gladstone Financial Corporation November 15, 2006 Page 2 company’s two most recent fiscal years or any subsequent interim period through the effective date of dismissal.
* * * *
As appropriate, please amend your filing and respond to these comments, via EDGAR, within five business days or tell us when you will respond. Please furnish a cover letter with your amendment that keys your responses to our comments and provides any requested information. Detailed cover le tters greatly facilitate our review. Please understand that we may have additional comm ents 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 to be certain that the filing includes all in formation required under the Securities Exchange Act of 1934 and th at they have provided all information investors require for an informed invest ment decision. Since the company and its management are in possession of all facts re lating 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 advise d that the Division of Enfo rcement has access to all information you provide to the staff of the Divi sion of Corporation Fi nance in our review of your filing or in response to our comments on your filing.
If you have any questions, please call Kenya Wright Gumbs at (202) 551-3373.
S i n c e r e l y ,
Robert S. Littlepage Accountant Branch Chief
Show Raw Text
Mail Stop 3720
November 15, 2006
Mr. Arthur F. Birmingham
Executive Vice President
and Chief Financial Officer
Peapack-Gladstone Financial Corporation
158 Rout 206
Peapack-Gladstone, NJ 07934
Re: Peapack-Gladstone Financial Corporation
Item 4.01 Form 8-K
Filed November 15, 2006
File No. 001-16197
Dear Mr. Birmingham:
We have reviewed your filing and have the following comments. Where
indicated, we think you should re vise your document in response to these comments. If
you disagree, we will consider your explanation as to why our comment is inapplicable or
a revision is unnecessary. Please be as deta iled as necessary in your explanation. In
some of our comments, we may ask you to provi de us with more information so we may
better understand your disclosure. After re viewing this information, we may raise
additional comments.
Please understand that the purpose of our re view 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.
1. Please file a revised Form 8-K upon the co mpletion of the audit of the company’s
consolidated financial statements as of and for the year ended December 31, 2006,
as discussed in Item 4.01 of your Form 8-K filed on November 14, 2006, to
include the date upon which the dismissal of your auditors is effective. Please
note that all portions of the Form 8- K should be updated, including the section
regarding any disagreements. A new E xhibit 16 letter will also be required.
2. Please revise your disclosure to specif ically state whether there were any
disagreements, as described in Item 304( a)(1)(iv) of Regulat ion S-K, during the
Mr. Arthur F. Birmingham
Peapack-Gladstone Financial Corporation
November 15, 2006 Page 2
company’s two most recent fiscal years or any subsequent interim period through
the effective date of dismissal.
* * * *
As appropriate, please amend your filing and respond to these comments, via
EDGAR, within five business days or tell us when you will respond. Please furnish a cover letter with your amendment that keys your responses to our comments and provides
any requested information. Detailed cover le tters greatly facilitate our review. Please
understand that we may have additional comm ents 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 to be certain that the filing includes all in formation required under
the Securities Exchange Act of 1934 and th at they have provided all information
investors require for an informed invest ment decision. Since the company and its
management are in possession of all facts re lating 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 advise d that the Division of Enfo rcement has access to all
information you provide to the staff of the Divi sion of Corporation Fi nance in our review
of your filing or in response to our comments on your filing.
If you have any questions, please call Kenya Wright Gumbs at (202) 551-3373.
S i n c e r e l y ,
Robert S. Littlepage
Accountant Branch Chief