SEC Comment Letter for PEAPACK GLADSTONE FINANCIAL CORP (PGC) (CIK 0001050743) (PGC) — Oct 15, 2012
PEAPACK GLADSTONE FINANCIAL CORP (PGC) (CIK 0001050743)
Date: Oct. 15, 2012 · CIK: 0001050743 · Accession: 0000000000-12-056695
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 001-16197
Referenced dates: August 7, 2012, September 10, 2012
Letter
October 15 , 2012 Via E -mail Jeffrey J. Carfora Executive Vice President and Chief Financial Officer Peapack -Gladstone Financial Corporation 500 Hills Drive, Suite 300 Bedminster, NJ 07921
Re: Peapack -Gladstone Financial Corporation Form 10 -K for th e Fiscal Year Ended December 31 , 2011 Filed March 15 , 2012 Form 10 -Q for the Quarterly Period Ended March 31, 2012 Filed May 9 , 2012 Form 10 -Q for the Quarterly Period Ended June 30, 2012 Filed August 9, 2012 File No. 001-16197
Dear Mr. Carfora :
We have reviewed your response letter dated September 10, 2012 and have the following comment. In our comment , we may ask you to provide us with information so we may better understand your disclosure.
Please respond to this le tter within ten business days by providing the requested information, or by advising us when you will provide the requested response. If you do not belie ve our comment applies to your facts and circumstances , please tell us why in your response.
After reviewing any information you provide in response to this comment , we may have additional comments.
Form 10 -K for the Fiscal Year Ended December 31, 2011
Exhibit 1 3 1. Summary of Significant Accounting Policies Loans, page 48
1. We have reviewed your response to prior comment five from our letter dated August 7, 2012. In your response you state that modifications of residential mortgage loans for which a borrower i s experiencing a temporary hardship may include a deferment of up to six months of loan payments which, in Management’s judgment, does not reflect a
Jeffrey J. Carfora Peapack -Gladstone Financial Corporation October 15 , 2012 Page 2
significant delay, given that these loans typically have original maturities of 15 to 30 years. Please pro vide us with the following as it relates to these short -term loan modifications:
Discuss the types of temporary hardships experienced by these borrowers; Quantify the amounts of loans that have been modified using this type of workout strategy in each period presented. Clarify whether these short -term modifications are only made on mortgage loans or various types of loans; Provide additional analysis supporting your conclusio n that these short -term modifications should not be classified as troubled debt restructurings; Tell us how the loans are classified (performing vs. non -performing) and whether they continue to accrue interest; and Describe whether these loans are include d in your ASC 450 -20 or ASC 310 -10 impairment analysis.
You may contact William Schroeder , Staff Accountant, at (202) 551 -3294 or me at (202) 551-3474 if you have questions regarding our comment on the financial statements and related matters .
Sincerely,
/s/ Sharon Blume
Show Raw Text
October 15 , 2012 Via E -mail Jeffrey J. Carfora Executive Vice President and Chief Financial Officer Peapack -Gladstone Financial Corporation 500 Hills Drive, Suite 300 Bedminster, NJ 07921 Re: Peapack -Gladstone Financial Corporation Form 10 -K for th e Fiscal Year Ended December 31 , 2011 Filed March 15 , 2012 Form 10 -Q for the Quarterly Period Ended March 31, 2012 Filed May 9 , 2012 Form 10 -Q for the Quarterly Period Ended June 30, 2012 Filed August 9, 2012 File No. 001-16197 Dear Mr. Carfora : We have reviewed your response letter dated September 10, 2012 and have the following comment. In our comment , we may ask you to provide us with information so we may better understand your disclosure. Please respond to this le tter within ten business days by providing the requested information, or by advising us when you will provide the requested response. If you do not belie ve our comment applies to your facts and circumstances , please tell us why in your response. After reviewing any information you provide in response to this comment , we may have additional comments. Form 10 -K for the Fiscal Year Ended December 31, 2011 Exhibit 1 3 1. Summary of Significant Accounting Policies Loans, page 48 1. We have reviewed your response to prior comment five from our letter dated August 7, 2012. In your response you state that modifications of residential mortgage loans for which a borrower i s experiencing a temporary hardship may include a deferment of up to six months of loan payments which, in Management’s judgment, does not reflect a Jeffrey J. Carfora Peapack -Gladstone Financial Corporation October 15 , 2012 Page 2 significant delay, given that these loans typically have original maturities of 15 to 30 years. Please pro vide us with the following as it relates to these short -term loan modifications: Discuss the types of temporary hardships experienced by these borrowers; Quantify the amounts of loans that have been modified using this type of workout strategy in each period presented. Clarify whether these short -term modifications are only made on mortgage loans or various types of loans; Provide additional analysis supporting your conclusio n that these short -term modifications should not be classified as troubled debt restructurings; Tell us how the loans are classified (performing vs. non -performing) and whether they continue to accrue interest; and Describe whether these loans are include d in your ASC 450 -20 or ASC 310 -10 impairment analysis. You may contact William Schroeder , Staff Accountant, at (202) 551 -3294 or me at (202) 551-3474 if you have questions regarding our comment on the financial statements and related matters . Sincerely, /s/ Sharon Blume Sharon Blume Assistant Chief Accountant