SEC Comment Letter for PATRIOT NATIONAL BANCORP INC (PNBK) (CIK 0001098146) (PNBK) — Aug 2, 2005
PATRIOT NATIONAL BANCORP INC (PNBK) (CIK 0001098146)
Date: Aug. 2, 2005 · CIK: 0001098146 · Accession: 0000000000-05-039838
AI Filing Summary & Sentiment
File numbers found in text: 333-124312
Letter
June 27, 2005 Mail Stop 4561 Charles F. Howell President Patriot National Bancorp, Inc. 900 Bedford Street Stamford, Connecticut 06901
Re: Patriot National Bancorp, Inc. Amendment No. 1 to Form SB-2 filed on June 21, 2005 File No. 333-124312
Dear Mr. Howell:
We have reviewed the amendment to your filing and have the following comments. Where indicated, we think you should revise your document in response to these comments. If you disagree, we will consider your explanation as to why our comment is inapplicable or a revision is unnecessary. Please be as detailed as necessary in your explanation. In some of our comments, we may ask you to provide us with supplemental information so we may better understand your disclosure. After reviewing this information, we may or may not raise additional comments.
The purpose of our review process is to assist you in your compliance with the applicable disclosure requirements and to enhance the overall disclosure in your filing. We look forward to working with you in these respects. We welcome any questions you may have about our comments or on any other aspect of our review. Feel free to call us at the telephone numbers listed at the end of this letter.
Standby Purchase Agreements, page 28
1. Please advise us whether or not you anticipate that either Mr. Lewis or Mr. De Caro will be a standby purchaser. If either of them will be, disclose by footnote what their percentage ownership of you company will be, assuming that they were to make the maximum purchase that they have committed to.
Potential Problem Loans, page 44
2. We note your supplemental response to our prior comment 8. Please revise your disclosure to describe the nature of your significant non accrual loans. Disclose the changes in status or performance subsequent to December 31, 2004 and March 31, 2005. Quantify the amount of any specific allowance attributable to these non-accrual loans as of December 31, 2004 and March 31, 2005.
Closing Comment
As appropriate, please amend your registration statement in response to these comments. You may wish to provide us with marked copies of the amendment to expedite our review. Please furnish a cover letter with your amendment 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 amendment and responses to our comments.
We direct your attention to Rules 460 and 461 regarding requesting acceleration of a registration statement. Please allow adequate time after the filing of any amendment for further review before submitting a request for acceleration. Please provide this request at least two business days in advance of the requested effective date.
Accounting questions may be directed to Chris Harley at (202) 551-3695 or to Joyce Sweeney at (202) 551-3449. All other questions may be directed to me at (202) 551-3418.
Sincerely,
William Friar
Senior Financial Analyst
Show Raw Text
<DOCUMENT>
<TYPE>LETTER
<SEQUENCE>1
<FILENAME>filename1.txt
<TEXT>
June 27, 2005
Mail Stop 4561
Charles F. Howell
President
Patriot National Bancorp, Inc.
900 Bedford Street
Stamford, Connecticut 06901
Re: Patriot National Bancorp, Inc.
Amendment No. 1 to Form SB-2 filed on June 21, 2005
File No. 333-124312
Dear Mr. Howell:
We have reviewed the amendment to your filing and have the
following comments. Where indicated, we think you should revise
your
document in response to these comments. If you disagree, we will
consider your explanation as to why our comment is inapplicable or
a
revision is unnecessary. Please be as detailed as necessary in
your
explanation. In some of our comments, we may ask you to provide
us
with supplemental information so we may better understand your
disclosure. After reviewing this information, we may or may not
raise additional comments.
The purpose of our review process is to assist you in your
compliance with the applicable disclosure requirements and to
enhance
the overall disclosure in your filing. We look forward to working
with you in these respects. We welcome any questions you may have
about our comments or on any other aspect of our review. Feel
free
to call us at the telephone numbers listed at the end of this
letter.
Standby Purchase Agreements, page 28
1. Please advise us whether or not you anticipate that either Mr.
Lewis or Mr. De Caro will be a standby purchaser. If either of
them
will be, disclose by footnote what their percentage ownership of
you
company will be, assuming that they were to make the maximum
purchase
that they have committed to.
Potential Problem Loans, page 44
2. We note your supplemental response to our prior comment 8.
Please
revise your disclosure to describe the nature of your significant
non
accrual loans. Disclose the changes in status or performance
subsequent to December 31, 2004 and March 31, 2005. Quantify the
amount of any specific allowance attributable to these non-accrual
loans as of December 31, 2004 and March 31, 2005.
Closing Comment
As appropriate, please amend your registration statement in
response to these comments. You may wish to provide us with
marked
copies of the amendment to expedite our review. Please furnish a
cover letter with your amendment 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
amendment and responses to our comments.
We direct your attention to Rules 460 and 461 regarding
requesting acceleration of a registration statement. Please allow
adequate time after the filing of any amendment for further review
before submitting a request for acceleration. Please provide this
request at least two business days in advance of the requested
effective date.
Accounting questions may be directed to Chris Harley at (202)
551-3695 or to Joyce Sweeney at (202) 551-3449. All other
questions
may be directed to me at (202) 551-3418.
Sincerely,
William Friar
Senior Financial Analyst
cc: William W. Bouton III, Esq.
Kerry John Tomasevich, Esq.
Tyler Cooper & Alcorn, LLP
185 Asylum Avenue
City Place 35th. Floor
Hartford, Ct. 06103-3488
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Mr. Charles F. Howell
Patriot National Bancorp, Inc
June 27, 2005
Page 2
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</DOCUMENT>