SEC Company Response from PEAPACK GLADSTONE FINANCIAL CORP (PGC) (CIK 0001050743) (PGC) — Nov 17, 2006
PEAPACK GLADSTONE FINANCIAL CORP (PGC) (CIK 0001050743)
Date: Nov. 17, 2006 · CIK: 0001050743 · Accession: 0000914317-06-003071
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 001-16197
Letter
VIA EDGAR United States Securities and Exchange Commission Division of Corporate Finance Mail Stop 3720 Washington, D.C. 20549 Attention: Robert S. Littlepage, Accountant Branch Chief
Re: Peapack-Gladstone Financial Corporation Item 4.01 Form 8-K Filed November 14, 2006 File No. 001-16197
Dear Mr. Littlepage:
We have reviewed the November 15, 2006 comment letter issued by the staff of the United States Securities and Exchange Commission (the "Commission") and addressed to Peapack-Gladstone Financial Corporation (the "Corporation" or "we") relating to the Corporation's Current Report on Form 8-K dated November 14, 2006. Set forth below is our response to the Staff's comments. For ease of the Staff's review, we have included the Staff's comment preceding our response.
Staff Comment -------------
1. Please file a revised Form 8-K upon the completion 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 Exhibit 16 letter will also be required.
Response --------
We will file a Form 8-K/A upon the completion of the audit of the Corporation's consolidated financial statements as of and for the year ended December 31, 2006 to include the date upon which the dismissal of our auditors, KPMG LLP ("KPMG"), is effective. The Form 8-K/A, including the section regarding any disagreements, will be updated through the effective date of the dismissal of KPMG and include a new Exhibit 16 letter.
<PAGE>
Staff Comment -------------
2. Please revise your disclosure to specifically state whether there were any disagreements, as described in Item 304(a)(I)(iv) of Regulation S-K, during the company's two most recent fiscal years or any subsequent interim period through the effective date of dismissal.
Response --------
We are filing on the date hereof a Form 8-K/A to revise our disclosure to specifically state that there were no disagreements, as described in Item 304(a)(I)(iv) of Regulation S-K, during the Corporation's two most recent fiscal years and the subsequent interim period through November 10, 2006. The third paragraph of the Form 8-K/A reads as follows:
"During the two fiscal years ended December 31, 2005, and the subsequent interim period through November 10, 2006, there were no (1) disagreements with KPMG on any matter of accounting principles or practices, financial statement disclosure, or auditing scope or procedures, which disagreements if not resolved to KPMG's satisfaction would have caused KPMG to make reference in connection with their opinion to the subject matter of the disagreements in its audit reports on the consolidated financial statements of the Corporation or (2) "reportable events" as defined in Item 304(a)(1)(v) of Regulation S-K."
By way of this letter, we acknowledge that (i) the Corporation is responsible for the adequacy and accuracy of the disclosure in the filing; (ii) 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 (iii) the Corporation 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.
We trust that these responses adequately address the Staff's comments. However, if you have any points that that you would like to discuss further, please contact the undersigned at (908) 719-4308.
Very truly yours,
PEAPACK-GLADSTONE FINANCIAL CORPORATION
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November 17, 2006
VIA EDGAR
United States Securities and Exchange Commission
Division of Corporate Finance
Mail Stop 3720
Washington, D.C. 20549
Attention: Robert S. Littlepage, Accountant Branch Chief
Re: Peapack-Gladstone Financial Corporation
Item 4.01 Form 8-K
Filed November 14, 2006
File No. 001-16197
Dear Mr. Littlepage:
We have reviewed the November 15, 2006 comment letter issued by the staff
of the United States Securities and Exchange Commission (the "Commission") and
addressed to Peapack-Gladstone Financial Corporation (the "Corporation" or "we")
relating to the Corporation's Current Report on Form 8-K dated November 14,
2006. Set forth below is our response to the Staff's comments. For ease of the
Staff's review, we have included the Staff's comment preceding our response.
Staff Comment
-------------
1. Please file a revised Form 8-K upon the completion 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 Exhibit 16 letter will also be required.
Response
--------
We will file a Form 8-K/A upon the completion of the audit of the
Corporation's consolidated financial statements as of and for the year ended
December 31, 2006 to include the date upon which the dismissal of our auditors,
KPMG LLP ("KPMG"), is effective. The Form 8-K/A, including the section regarding
any disagreements, will be updated through the effective date of the dismissal
of KPMG and include a new Exhibit 16 letter.
<PAGE>
Staff Comment
-------------
2. Please revise your disclosure to specifically state whether there were any
disagreements, as described in Item 304(a)(I)(iv) of Regulation S-K,
during the company's two most recent fiscal years or any subsequent
interim period through the effective date of dismissal.
Response
--------
We are filing on the date hereof a Form 8-K/A to revise our disclosure to
specifically state that there were no disagreements, as described in Item
304(a)(I)(iv) of Regulation S-K, during the Corporation's two most recent fiscal
years and the subsequent interim period through November 10, 2006. The third
paragraph of the Form 8-K/A reads as follows:
"During the two fiscal years ended December 31, 2005, and the subsequent
interim period through November 10, 2006, there were no (1) disagreements with
KPMG on any matter of accounting principles or practices, financial statement
disclosure, or auditing scope or procedures, which disagreements if not resolved
to KPMG's satisfaction would have caused KPMG to make reference in connection
with their opinion to the subject matter of the disagreements in its audit
reports on the consolidated financial statements of the Corporation or (2)
"reportable events" as defined in Item 304(a)(1)(v) of Regulation S-K."
By way of this letter, we acknowledge that (i) the Corporation is
responsible for the adequacy and accuracy of the disclosure in the filing; (ii)
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
(iii) the Corporation 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.
We trust that these responses adequately address the Staff's comments.
However, if you have any points that that you would like to discuss further,
please contact the undersigned at (908) 719-4308.
Very truly yours,
PEAPACK-GLADSTONE FINANCIAL CORPORATION
By: /s/ Arthur F. Birmingham
--------------------------------------------------
Name: Arthur F. Birmingham
Title: Executive Vice President and Chief Financial
Officer
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