SEC Comment Letter for PEAPACK GLADSTONE FINANCIAL CORP (PGC) (CIK 0001050743) (PGC) — Nov 14, 2012
PEAPACK GLADSTONE FINANCIAL CORP (PGC) (CIK 0001050743)
Date: Nov. 14, 2012 · CIK: 0001050743 · Accession: 0000000000-12-062065
AI Filing Summary & Sentiment
Reasoning
Referenced dates: October 15, 2012
Letter
November 14 , 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 File No. 001 -16197
Dear Mr. Carfora :
We have reviewed your filing and have the following comment s. In some of our comment s, we may ask you to provide us with information so we may better understand your disclosure.
Please respond to this letter within ten business days by amending your filing, by providing the requested information, or by advising us when you will provide the requested response. Where we have requested changes in future filings, please include a draft of your proposed disclosures that clearly identifies new or revised disclosures. If you do not belie ve our comment s apply to your facts and circumstances or do not believe an amendment is appropriate, please tell us why in your response.
After reviewing any amendment to your filing and the information you provide in response to these commen ts, including the draft of your proposed disclosures, we may have additional comments.
Form 10 -K for the Fiscal Year Ended Dec ember 31, 2011
Exhibit 13
1. Summary of Significant Accounting Policies
Loans, page 48
1. We have reviewed your response to prior comment one from our letter dated October 15, 2012. We believe a three to six month delay in timing of the restructured payment period
Jeffrey J. Carfora Peapack -Gladstone Financial Corporation November 14 , 2012 Page 2
is not insignificant to the frequency of payments due under the debt. Please re vise future filings to update your accounting policy and related disclosures.
2. In your response, you state that “while in forbearance period, although these loans are not classified as nonaccrual, the Bank does not record any income from the loans since payments are not being received.” Please revise future filings to classify the se loans as nonaccrual , as you are not recording any income on them.
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 the information the Securities Exchange Act of 1934 and all applicable Exchange Act rules require. Since the company and its management are in possession of all facts relating to a company’s disclosure, they are responsib le for the accuracy and adequacy of the disclosures they have made.
In responding to our comment s, please provide a written 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.
You may contact William Schroeder , Staff Accountant, at (202) 551 -3294 or me at (202) 551-3474 if you have questions regarding our comment s on the financial statements and related matters .
Sincerely,
/s/ Sharon M. Blume
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November 14 , 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 File No. 001 -16197 Dear Mr. Carfora : We have reviewed your filing and have the following comment s. In some of our comment s, we may ask you to provide us with information so we may better understand your disclosure. Please respond to this letter within ten business days by amending your filing, by providing the requested information, or by advising us when you will provide the requested response. Where we have requested changes in future filings, please include a draft of your proposed disclosures that clearly identifies new or revised disclosures. If you do not belie ve our comment s apply to your facts and circumstances or do not believe an amendment is appropriate, please tell us why in your response. After reviewing any amendment to your filing and the information you provide in response to these commen ts, including the draft of your proposed disclosures, we may have additional comments. Form 10 -K for the Fiscal Year Ended Dec ember 31, 2011 Exhibit 13 1. Summary of Significant Accounting Policies Loans, page 48 1. We have reviewed your response to prior comment one from our letter dated October 15, 2012. We believe a three to six month delay in timing of the restructured payment period Jeffrey J. Carfora Peapack -Gladstone Financial Corporation November 14 , 2012 Page 2 is not insignificant to the frequency of payments due under the debt. Please re vise future filings to update your accounting policy and related disclosures. 2. In your response, you state that “while in forbearance period, although these loans are not classified as nonaccrual, the Bank does not record any income from the loans since payments are not being received.” Please revise future filings to classify the se loans as nonaccrual , as you are not recording any income on them. 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 the information the Securities Exchange Act of 1934 and all applicable Exchange Act rules require. Since the company and its management are in possession of all facts relating to a company’s disclosure, they are responsib le for the accuracy and adequacy of the disclosures they have made. In responding to our comment s, please provide a written 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. You may contact William Schroeder , Staff Accountant, at (202) 551 -3294 or me at (202) 551-3474 if you have questions regarding our comment s on the financial statements and related matters . Sincerely, /s/ Sharon M. Blume Sharon M. Blume Assistant Chief Accountant