SEC Comment Letter for BERKSHIRE HILLS BANCORP INC (BHLB) (CIK 0001108134) (BBT) — Jun 26, 2015
BERKSHIRE HILLS BANCORP INC (BHLB) (CIK 0001108134)
Date: June 26, 2015 · CIK: 0001108134 · Accession: 0000000000-15-033724
AI Filing Summary & Sentiment
Letter
June 26, 2015 Michael P. Daly President and Chief Executive Officer Berkshire Hills Bancorp, Inc. 24 North Street Pittsfield, MA 01201
Re: Berkshire Hills Bancorp, Inc. Registration Statement on Form S -4 Filed June 19 , 2015 File No. 333 -205096
Dear Mr. Daly :
This is to advise you that we have not reviewed and will not review your registration statement .
We urge all persons who are responsible for the accuracy and adequacy of the disclosure in the filing to be certain that the filing includes the information the Securities Act of 193 3 and all applicable Securities Act rules 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 the event you request acceleration of the effective date of the pending regist ration statement , please provide a written statement from the company acknowledging that:
should the Commission or the staff, acting pursuant to delegated authority, declare the filing effective, it does not foreclose the Commission from taking any action wit h respect to the filing;
the action of the Commission or the staff, acting pursuant to delegated authority, in declaring the filing effective, does not relieve the company from its full responsibility for the adequacy and accuracy of the disclosure in th e filing; and
the company may not assert staff comments and the declaration of effectiveness as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.
Michael P. Daly Berkshire Hills Bancorp, Inc. June 26, 2015 Page 2
Please refer to Rules 460 an d 461 regarding requests for acceleration . We will consider a written request for acceleration of the effective date of the registration statement as confirmation of the fact that those requesting acceleration are aware of their respective responsibilitie s under the Securities Act of 1933 and the Securities Exchange Act of 1934 as they relate to the proposed public offering of the registered securities .
You may contact Joshua Samples , Staff Attorney, at (202) 551 -3199 with any questions.
Sincerely,
/s/ Era Anagnosti
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June 26, 2015 Michael P. Daly President and Chief Executive Officer Berkshire Hills Bancorp, Inc. 24 North Street Pittsfield, MA 01201 Re: Berkshire Hills Bancorp, Inc. Registration Statement on Form S -4 Filed June 19 , 2015 File No. 333 -205096 Dear Mr. Daly : This is to advise you that we have not reviewed and will not review your registration statement . We urge all persons who are responsible for the accuracy and adequacy of the disclosure in the filing to be certain that the filing includes the information the Securities Act of 193 3 and all applicable Securities Act rules 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 the event you request acceleration of the effective date of the pending regist ration statement , please provide a written statement from the company acknowledging that: should the Commission or the staff, acting pursuant to delegated authority, declare the filing effective, it does not foreclose the Commission from taking any action wit h respect to the filing; the action of the Commission or the staff, acting pursuant to delegated authority, in declaring the filing effective, does not relieve the company from its full responsibility for the adequacy and accuracy of the disclosure in th e filing; and the company may not assert staff comments and the declaration of effectiveness as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States. Michael P. Daly Berkshire Hills Bancorp, Inc. June 26, 2015 Page 2 Please refer to Rules 460 an d 461 regarding requests for acceleration . We will consider a written request for acceleration of the effective date of the registration statement as confirmation of the fact that those requesting acceleration are aware of their respective responsibilitie s under the Securities Act of 1933 and the Securities Exchange Act of 1934 as they relate to the proposed public offering of the registered securities . You may contact Joshua Samples , Staff Attorney, at (202) 551 -3199 with any questions. Sincerely, /s/ Era Anagnosti Era Anagnosti Legal Branch Chief cc: Marc Levy Luse Gorman, PC