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SEC Company Response from PENNSYLVANIA COMMERCE BANCORP INC (CIK 0001085706) — Oct 27, 2004

PENNSYLVANIA COMMERCE BANCORP INC (CIK 0001085706)
Date: Oct. 27, 2004 · CIK: 0001085706 · Accession: 0000950159-04-000929

AI Filing Summary & Sentiment

File numbers found in text: 333-118236

Date
October 27, 2004
Author
By: /s/ Mark A. Zody
Form
CORRESP
Company
PENNSYLVANIA COMMERCE BANCORP INC (CIK 0001085706)

Letter

Pennsylvania Commerce Bancorp, Inc. 100 Senate Avenue P.O. Box 8599 Camp Hill, PA 17001-8599 October 27, 2004 VIA EDGAR AND FACSIMILE ----------------------- (202) 942-9530 Securities and Exchange Commission Division of Corporation Finance 450 Fifth Street, NW Washington, DC 20549

Re: Pennsylvania Commerce Bancorp, Inc. (the "Company") Registration Statement on Form S-1, as amended File No. 333-118236 ("Registration Statement")

Dear Sir/Madam:

The Company hereby requests that the above-referenced Registration Statement be declared effective by the Commission on Thursday, October 28, 2004 at 3:00 p.m. Eastern time, or as soon thereafter as is practical.

In addition, the Company acknowledges that:

o should the Commission or the staff, acting pursuant to delegated authority, declare the Registration Statement effective, it does not foreclose the Commission from taking any action with respect to the Registration Statement;

o the action of the Commission or the staff, acting pursuant to the delegated authority, in declaring the Registration Statement effective, does not relieve the Company from its full responsibility for the adequacy and accuracy of the disclosure in the Registration Statement; and

o the Company may not assert this action as defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.

Sincerely,

PENNSYLVANIA COMMERCE BANCORP, INC.

By: /s/ Mark A. Zody -------------------------------------------- Mark A. Zody Chief Financial Officer and Treasurer

<PAGE>

October 27, 2004

Securities and Exchange Commission Division of Corporation Finance 450 Fifth Street, N.W. Judiciary Plaza Washington, D.C. 20549

Re: Pennsylvania Commerce Bancorp, Inc. Registration Statement No. 333-118236 -------------------------------------

Ladies and Gentlemen:

In accordance with Rule 461 of the Rules and Regulations of the Securities and Exchange Commission promulgated under the Securities Act of 1933, as amended, we hereby join Pennsylvania Commerce Bancorp, Inc. (the "Company") in requesting that the Company's above-referenced registration statement on Form S-1 be declared effective on Thursday, October 28, 2004, at 3:00 p.m. Eastern time, or as soon thereafter as is practicable.

Very truly yours,
SANDLER O'NEILL & PARTNERS, L.P.

Show Raw Text
<DOCUMENT>
<TYPE>CORRESP
<SEQUENCE>1
<FILENAME>filename1.txt
<TEXT>

                       Pennsylvania Commerce Bancorp, Inc.
                                100 Senate Avenue
                                  P.O. Box 8599
                            Camp Hill, PA 17001-8599

                                                               October 27, 2004

VIA EDGAR AND FACSIMILE
-----------------------
(202) 942-9530
Securities and Exchange Commission
Division of Corporation Finance
450 Fifth Street, NW
Washington, DC 20549

Re:      Pennsylvania Commerce Bancorp, Inc. (the "Company")
         Registration Statement on Form S-1, as amended
         File No. 333-118236 ("Registration Statement")

Dear Sir/Madam:

         The Company hereby requests that the above-referenced Registration
Statement be declared effective by the Commission on Thursday, October 28, 2004
at 3:00 p.m. Eastern time, or as soon thereafter as is practical.

         In addition, the Company acknowledges that:

          o         should the  Commission  or the  staff,  acting  pursuant  to
                    delegated  authority,  declare  the  Registration  Statement
                    effective,  it does not foreclose the Commission from taking
                    any action with respect to the Registration Statement;

          o         the action of the Commission or the staff,  acting  pursuant
                    to the delegated  authority,  in declaring the  Registration
                    Statement  effective,  does not relieve the Company from its
                    full  responsibility  for the  adequacy  and accuracy of the
                    disclosure in the Registration Statement; and

          o         the  Company  may not assert  this  action as defense in any
                    proceeding  initiated by the  Commission or any person under
                    the federal securities laws of the United States.

                              Sincerely,

                              PENNSYLVANIA COMMERCE BANCORP, INC.

                              By:   /s/ Mark A. Zody
                                 --------------------------------------------
                                        Mark A. Zody
                                        Chief Financial Officer and Treasurer

<PAGE>

October 27, 2004

Securities and Exchange Commission
Division of Corporation Finance
450 Fifth Street, N.W.
Judiciary Plaza
Washington, D.C.  20549

                                    Re:   Pennsylvania Commerce Bancorp, Inc.
                                          Registration Statement No. 333-118236
                                          -------------------------------------

Ladies and Gentlemen:

     In accordance  with Rule 461 of the Rules and Regulations of the Securities
and  Exchange  Commission  promulgated  under  the  Securities  Act of 1933,  as
amended, we hereby join Pennsylvania  Commerce Bancorp,  Inc. (the "Company") in
requesting that the Company's  above-referenced  registration  statement on Form
S-1 be declared  effective on Thursday,  October 28, 2004, at 3:00 p.m.  Eastern
time, or as soon thereafter as is practicable.

Very truly yours,

SANDLER O'NEILL & PARTNERS, L.P.

By:  Sandler O'Neill & Partners Corp.,
         the sole general partner

By:     /s/ Patricia A. Murphy
            ------------------
            Patricia A. Murphy
            Authorized Signatory

</TEXT>
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