SEC Comment Letter for BERKSHIRE HILLS BANCORP INC (BHLB) (CIK 0001108134) (BBT) — Jan 18, 2011
BERKSHIRE HILLS BANCORP INC (BHLB) (CIK 0001108134)
Date: Jan. 18, 2011 · CIK: 0001108134 · Accession: 0000000000-11-003456
AI Filing Summary & Sentiment
File numbers found in text: 333-170798
Referenced dates: December 16, 2010
Letter
January 18, 2011
Mr. Michael P. Daly President and Chief Executive Officer Berkshire Hills Bancorp, Inc. 24 North Street Pittsfield, Massachusetts 01201 Re: Berkshire Hills Bancorp, Inc. Amendment No. 1 to Registrati on Statement on Form S-4 Filed January 12, 2011 File No. 333-170798 Dear Mr. Daly: We have limited our review of your amended re gistration statement to those portions that relate to our comments dated December 16, 2010. In some of our comments, we may ask you to provide us with information so we may better understand your disclosure. Please respond to this letter by amending your registration statement and providing the requested information. If you do not believe our comments apply to your facts and circumstances or do not believe an amendment is appropriate, please tell us why in your response. After reviewing any amendment to your re gistration statement and the information you provide in response to these comments , we may have additional comments. Proxy/Prospectus Cover Page
1. We reissue our prior comment 1 to revise the third paragr aph inform holders that to perfect dissenters/appraisal rights they must either vote against the merger or not send in a proxy . In addition, make similar disclosure in the Rome “Notice of Special Meeting of Stockholders”.
Mr. Michael P. Daly Berkshire Hills Bancorp, Inc. January 18, 2011 Page 2 Q&A, page 2
2. We reissue our prior comment 2 to revise your disclosure to substitute the current language with something similar to “either return a proxy voting against the merger or not return the proxy ”.
Please contact Erin Magnor at (202) 551-3454 or me at (202) 551-3434 with any questions.
S i n c e r e l y ,
M i c h a e l C l a m p i t t S e n i o r A t t o r n e y
cc. (facsimile only) Marc Levy, Esq. Luse Gorman Pomerenk & Schick LLP (202) 362-2902
Show Raw Text
January 18, 2011
Mr. Michael P. Daly President and Chief Executive Officer Berkshire Hills Bancorp, Inc. 24 North Street Pittsfield, Massachusetts 01201
Re: Berkshire Hills Bancorp, Inc.
Amendment No. 1 to Registrati on Statement on Form S-4
Filed January 12, 2011
File No. 333-170798
Dear Mr. Daly:
We have limited our review of your amended re gistration statement to those portions that
relate to our comments dated December 16, 2010. In some of our comments, we may ask you to provide us with information so we may better understand your disclosure.
Please respond to this letter by amending your registration statement and providing the
requested information. If you do not believe our comments apply to your facts and
circumstances or do not believe an amendment is appropriate, please tell us why in your
response.
After reviewing any amendment to your re gistration statement and the information you
provide in response to these comments , we may have additional comments.
Proxy/Prospectus Cover Page
1. We reissue our prior comment 1 to revise the third paragr aph inform holders that to
perfect dissenters/appraisal rights they must either vote against the merger or not send in
a proxy . In addition, make similar disclosure in the Rome “Notice of Special Meeting of
Stockholders”.
Mr. Michael P. Daly
Berkshire Hills Bancorp, Inc. January 18, 2011 Page 2 Q&A, page 2
2. We reissue our prior comment 2 to revise your disclosure to substitute the current
language with something similar to “either return a proxy voting against the merger or
not return the proxy ”.
Please contact Erin Magnor at (202) 551-3454 or me at (202) 551-3434 with any
questions.
S i n c e r e l y ,
M i c h a e l C l a m p i t t
S e n i o r A t t o r n e y
cc. (facsimile only)
Marc Levy, Esq. Luse Gorman Pomerenk & Schick LLP (202) 362-2902