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SEC Comment Letter for HCSB FINANCIAL CORP (CIK 0001091491) — Oct 13, 2005

HCSB FINANCIAL CORP (CIK 0001091491)
Date: Oct. 13, 2005 · CIK: 0001091491 · Accession: 0000000000-05-052442

AI Filing Summary & Sentiment

Referenced dates: September 21, 2005

Date
October 13, 2005
Author
Joyce Sweeney
Form
UPLOAD
Company
HCSB FINANCIAL CORP (CIK 0001091491)

Letter

October 13, 2005 Mail Stop 4561 James R. Clarkson President and Chief Executive Officer HCSB Financial Services Corporation 5201 Broad Street Loris, South Carolina 29569

Re: HCSB Financial Services Corporation Form 10-KSB for the period ended December 31, 2004 File No. 0-26995

Dear Mr. Clarkson:

We have reviewed your September 21, 2005 response and have the following comments.

Form 10-KSB for the period ended December 31, 2004

Financial Statements

Note 7 - Derivative and Hedging Instruments, page 40

1. We note your supplemental response to comment 1 from our letter dated September 21, 2005. Please tell us whether your convertible advances automatically convert to a variable-rate when the FHLB exercises its option or if you must prepay the fixed-rate advance in cash unless you can negotiate a new advance. Provide us with the contractual excerpts that describe the conversion terms.

2. Please tell us how you considered the applicability of paragraph 68(d) of SFAS 133 since this paragraph specifically provides an exception for call and put rights that are mirrored and these instruments contain conversion features.

Please respond to these comments within 10 business days or tell us when you will provide us with a response. Please file your response letter on EDGAR. Please understand that we may have additional comments after reviewing your responses to our comments.

You may contact Sharon Johnson, Staff Accountant, at (202) 551- 3474 or me at (202) 551-3449 if you have questions.

Sincerely,
Joyce Sweeney
Branch Chief
??

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

      October 13, 2005

     Mail Stop 4561
     James R. Clarkson
President and Chief Executive Officer
HCSB Financial Services Corporation
5201 Broad Street
Loris, South Carolina 29569

      Re:	HCSB Financial Services Corporation
		Form 10-KSB for the period ended December 31, 2004
		File No. 0-26995

Dear Mr. Clarkson:

	We have reviewed your September 21, 2005 response and have
the
following comments.

Form 10-KSB for the period ended December 31, 2004

Financial Statements

Note 7 - Derivative and Hedging Instruments, page 40

1. We note your supplemental response to comment 1 from our letter
dated September 21, 2005.  Please tell us whether your convertible
advances automatically convert to a variable-rate when the FHLB
exercises its option or if you must prepay the fixed-rate advance
in
cash unless you can negotiate a new advance.  Provide us with the
contractual excerpts that describe the conversion terms.

2. Please tell us how you considered the applicability of
paragraph
68(d) of SFAS 133 since this paragraph specifically provides an
exception for call and put rights that are mirrored and these
instruments contain conversion features.

      Please respond to these comments within 10 business days or
tell us when you will provide us with a response.  Please file
your
response letter on EDGAR.  Please understand that we may have
additional comments after reviewing your responses to our
comments.

      You may contact Sharon Johnson, Staff Accountant, at (202)
551-
3474 or me at (202) 551-3449 if you have questions.

      Sincerely,

      Joyce Sweeney
								Branch Chief
??

??

??

??

James R. Clarkson
HCSB Financial Services Corporation
October 13, 2005
Page 1

</TEXT>
</DOCUMENT>