SEC Comment Letter for OHIO LEGACY CORP (CIK 0001096654) — Apr 20, 2005
OHIO LEGACY CORP (CIK 0001096654)
Date: April 20, 2005 · CIK: 0001096654 · Accession: 0000000000-05-019372
AI Filing Summary & Sentiment
Referenced dates: April 12, 2005
Letter
Mail Stop 0408 By U.S. Mail and facsimile to (330) 263-0063 Mr. L. Dwight Douce President, Chief Executive Officer, and Director Ohio Legacy Corp 305 West Liberty Street Wooster, OH 44691
Re: Ohio Legacy Corp Form 10-KSB filed March 22, 2005 Form 10-KSB/A filed April 5, 2005 File No. 0-31673
Dear Mr. Douce:
We have reviewed your response letter dated April 12, 2005, and have the following comments. Please respond to these comments within 10 business days or tell us when you will provide us with a response.
Form 10-KSB/A for the Year Ended December 31, 2004
2004 Annual Report to Shareholders
Note 2 - Securities - page 11
1. We note that as of December 31, 2004, you had available for sale securities with a fair value of approximately $11 million and unrealized losses for more than one year of $244,000. Please supplementally confirm to us whether you have both the intent and ability to retain these securities until the unrealized losses are recovered. Please also tell us whether you held any perpetual preferred stock of Fannie Mae and/or Freddie Mac as part of your U.S. Government-sponsored enterprises, and if so, please supplementally separately quantify the fair value, gross unrealized gains and losses, as appropriate.
* * * * * * *
Please respond to these comments within 10 business days or tell us when you will provide us with a response. Please furnish a cover letter that keys your responses to our comments and provides any requested supplemental information. Detailed cover letters greatly facilitate our review. Please understand that we may have additional comments after reviewing your responses to our comments.
We urge all persons who are responsible for the accuracy and adequacy of the disclosure in the filings reviewed by the staff to be certain that they have provided all information investors require. Since the company and its management are in possession of all facts relating to a company`s disclosure, they are responsible for the accuracy and adequacy of the disclosures they have made.
In connection with responding to our comments, please provide, in writing, a statement from the company acknowledging that:
* the company is responsible for the adequacy and accuracy of the disclosure in the filings; * staff comments or changes to disclosure in response to staff comments in the filings reviewed by the staff 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.
In addition, please be advised that the Division of Enforcement has access to all information you provide to the staff of the Division of Corporation Finance in our review of your filing or in response to our comments on your filing.
You may contact Lisa Haynes, Staff Accountant at (202) 824- or me at (202) 942-1783 if you have questions.
Sincerely,
John P. Nolan
Accounting Branch Chief
Show Raw Text
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<TYPE>LETTER
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<TEXT>
April 20, 2005
Mail Stop 0408
By U.S. Mail and facsimile to (330) 263-0063
Mr. L. Dwight Douce
President, Chief Executive Officer, and Director
Ohio Legacy Corp
305 West Liberty Street
Wooster, OH 44691
Re: Ohio Legacy Corp
Form 10-KSB filed March 22, 2005
Form 10-KSB/A filed April 5, 2005
File No. 0-31673
Dear Mr. Douce:
We have reviewed your response letter dated April 12, 2005,
and
have the following comments. Please respond to these comments
within
10 business days or tell us when you will provide us with a
response.
Form 10-KSB/A for the Year Ended December 31, 2004
2004 Annual Report to Shareholders
Note 2 - Securities - page 11
1. We note that as of December 31, 2004, you had available for
sale
securities with a fair value of approximately $11 million and
unrealized losses for more than one year of $244,000. Please
supplementally confirm to us whether you have both the intent and
ability to retain these securities until the unrealized losses are
recovered. Please also tell us whether you held any perpetual
preferred stock of Fannie Mae and/or Freddie Mac as part of your
U.S.
Government-sponsored enterprises, and if so, please supplementally
separately quantify the fair value, gross unrealized gains and
losses, as appropriate.
* * * * * * *
Please respond to these comments within 10 business days or
tell us when you will provide us with a response. Please furnish
a
cover letter that keys your responses to our comments and provides
any requested supplemental information. Detailed cover letters
greatly facilitate our review. Please understand that we may have
additional comments after reviewing your responses to our
comments.
We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filings reviewed by the staff to
be
certain that they have provided all information investors require.
Since the company and its management are in possession of all
facts
relating to a company`s disclosure, they are responsible for the
accuracy and adequacy of the disclosures they have made.
In connection with responding to our comments, please
provide,
in writing, a statement from the company acknowledging that:
* the company is responsible for the adequacy and accuracy of the
disclosure in the filings;
* staff comments or changes to disclosure in response to staff
comments in the filings reviewed by the staff 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.
In addition, please be advised that the Division of
Enforcement has access to all information you provide to the staff
of
the Division of Corporation Finance in our review of your filing
or
in response to our comments on your filing.
You may contact Lisa Haynes, Staff Accountant at (202) 824-
5398
or me at (202) 942-1783 if you have questions.
Sincerely,
John P. Nolan
Accounting Branch Chief
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Mr. L. Dwight Douce
Ohio Legacy Corp.
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