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UPLOAD Filing

PEAPACK GLADSTONE FINANCIAL CORP
Date: Sept. 10, 2025 · CIK: 0001050743 · Accession: 0000000000-25-009804

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File numbers found in text: 001-16197

Date
September 10, 2025
Author
Division of
Form
UPLOAD
Company
PEAPACK GLADSTONE FINANCIAL CORP

Letter

Re: Peapack-Gladstone Financial Corporation Form 10-K for the Fiscal Year Ended December 31, 2024 Form 8-K filed July 21, 2025 File No. 001-16197 Dear Frank A. Cavallaro:

September 10, 2025

Frank A. Cavallaro Senior Executive Vice President, Chief Financial Officer Peapack-Gladstone Financial Corporation 500 Hills Drive, Suite 300 Bedminster, NJ 07921

We have limited our review of your filing to the financial statements and related disclosures and have the following comments.

Please respond to this letter within ten business days by providing the requested information or advise us as soon as possible when you will respond. If you do not believe a comment applies to your facts and circumstances, please tell us why in your response.

After reviewing your response to this letter, we may have additional comments.

Form 10-K filed March 12, 2025 Managements Discussion and Analysis of Financial Condition and Results of Operations Wealth Management Division, page 54

1. We note assets under management ("AUM") and Assets under Administration ("AUA") increased from $10.9 billion at December 31, 2023 to $11.9 billion at December 31, 2024. In future filings, please address the following points within your disclosure: Provide a roll forward of your AUM from beginning to ending balances showing inflows, outflows and market appreciation or depreciation for the periods presented within your financial statements. Quantify your AUM and AUA balances separately, and to the extent possible, include a breakdown of AUM and the AUM roll forward by investment product or class in order show more meaningful changes in composition and trends impacting AUM. Disclose your weighted average fee rates and how they correlate to movements September 10, 2025 Page 2

within your AUM/AUA and changes in revenue for the periods presented within your financial statements.

Form 8-K filed July 21, 2025 Exhibit 99.1 Non-GAAP Financial Measures Reconciliation, page 18

2. We note that your presentation of tangible equity excluding other comprehensive loss and tangible book value per share excluding other comprehensive loss represent individually tailored accounting measures given that the adjustment to exclude the impact of other comprehensive loss has the effect of changing the recognition and measurement principles required to be applied in accordance with GAAP. Therefore, please remove the presentation of this measure from future filings. Refer to Question 100.04 of the Division of Corporation Finance s Compliance & Disclosure Interpretations on Non-GAAP Financial Measures and Rule 100(b) of Regulation G. In closing, we remind you that the company and its management are responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the staff.

Please contact Sarmad Makhdoom at 202-551-5776 or Lory Empie at 202-551-3714 with any questions.

Sincerely,
Division of
Corporation Finance
Office of Finance

Show Raw Text
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<TEXT>
 September 10, 2025

Frank A. Cavallaro
Senior Executive Vice President, Chief Financial Officer
Peapack-Gladstone Financial Corporation
500 Hills Drive, Suite 300
Bedminster, NJ 07921

 Re: Peapack-Gladstone Financial Corporation
 Form 10-K for the Fiscal Year Ended December 31, 2024
 Form 8-K filed July 21, 2025
 File No. 001-16197
Dear Frank A. Cavallaro:

 We have limited our review of your filing to the financial statements
and related
disclosures and have the following comments.

 Please respond to this letter within ten business days by providing the
requested
information or advise us as soon as possible when you will respond. If you do
not believe a
comment applies to your facts and circumstances, please tell us why in your
response.

 After reviewing your response to this letter, we may have additional
comments.

Form 10-K filed March 12, 2025
Managements Discussion and Analysis of Financial Condition and Results of
Operations
Wealth Management Division, page 54

1. We note assets under management ("AUM") and Assets under Administration
 ("AUA") increased from $10.9 billion at December 31, 2023 to $11.9
billion at
 December 31, 2024. In future filings, please address the following
points within your
 disclosure:
 Provide a roll forward of your AUM from beginning to ending balances
showing
 inflows, outflows and market appreciation or depreciation for the
periods
 presented within your financial statements.
 Quantify your AUM and AUA balances separately, and to the extent
possible,
 include a breakdown of AUM and the AUM roll forward by investment
product
 or class in order show more meaningful changes in composition and
trends
 impacting AUM.
 Disclose your weighted average fee rates and how they correlate to
movements
 September 10, 2025
Page 2

 within your AUM/AUA and changes in revenue for the periods presented
within
 your financial statements.

Form 8-K filed July 21, 2025
Exhibit 99.1
Non-GAAP Financial Measures Reconciliation, page 18

2. We note that your presentation of tangible equity excluding other
comprehensive loss
 and tangible book value per share excluding other comprehensive loss
represent
 individually tailored accounting measures given that the adjustment to
exclude the
 impact of other comprehensive loss has the effect of changing the
recognition and
 measurement principles required to be applied in accordance with GAAP.
Therefore,
 please remove the presentation of this measure from future filings.
Refer to Question
 100.04 of the Division of Corporation Finance s Compliance &
Disclosure
 Interpretations on Non-GAAP Financial Measures and Rule 100(b) of
Regulation G.
 In closing, we remind you that the company and its management are
responsible for
the accuracy and adequacy of their disclosures, notwithstanding any review,
comments,
action or absence of action by the staff.

 Please contact Sarmad Makhdoom at 202-551-5776 or Lory Empie at
202-551-3714
with any questions.

 Sincerely,

 Division of
Corporation Finance
 Office of Finance
</TEXT>
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