SEC Comment Letter for WGNB CORP (CIK 0001115568) — Sep 26, 2005
WGNB CORP (CIK 0001115568)
Date: Sept. 26, 2005 · CIK: 0001115568 · Accession: 0000000000-05-049565
AI Filing Summary & Sentiment
File numbers found in text: 000-30805
Letter
September 26, 2005 By U.S. Mail and Facsimile to (770) 830-2969 Steven J. Haack Treasurer WGNB Corp. 201 Maple Street P.O. Box 280 Carrollton, Georgia 30117
Re: WGNB Corp. Form 10-K for Fiscal Year Ended December 31, 2004 Filed March 28, 2005 File No. 000-30805
Dear Mr. Haack:
We have reviewed your filings and have the following comments. We have limited our review to the issues we have addressed in our 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 comments are inapplicable or revisions are unnecessary. Please be as detailed as necessary in your explanation. After reviewing this information, we may raise additional comments.
Please understand that 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 comment or any other aspect of our review. Feel free to call us at the telephone numbers listed at the end of this letter.
Consolidated Statement of Earnings, page F-4 1. Please explain to us your accounting policy for mortgage origination fees. In addition, tell us how your classification of mortgage origination fees as other income is consistent with paragraph 5 of SFAS 91.
Summary of Significant Accounting Policies Derivative Instruments and Hedging Activities, page F-11 2. Please advise us as follows with respect to the interest rate swap that you have designated as a fair value hedge of your fixed rate convertible FHLB advances:
* Provide us with and revise future filings to disclose the information required by paragraph 45 of SFAS 133.
* Identify whether you use the long-haul method, the short-cut method, or matched terms to assess the effectiveness of this hedging strategy.
* Describe how you assess hedge effectiveness and measure hedge ineffectiveness.
* If you apply the short cut method of assessing hedge effectiveness, tell us how you determined that this hedge met the conditions of paragraph 68 of SFAS 133 to qualify for such treatment.
As appropriate, please amend your filing and respond to these comments within 10 business days or tell us when you will provide us with a response. Please furnish a cover letter with your amendment that keys your response to our comments and provides any requested information. Detailed cover letters greatly facilitate our review. Please understand that we may have additional comments after reviewing your amendment and response to our comments.
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 all information required under the Securities Exchange Act of 1934 and that they have provided all information investors require for an informed investment decision. 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 filing;
* staff comments or changes to disclosure in response to staff comments 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 comment on your filing.
You may contact Margaret Fitzgerald at (202) 551-3556 or me at (202) 551-3426 if you have questions regarding comments on the financial statements and related matters.
Sincerely,
Angela Jackson
Senior Accountant
Show Raw Text
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Mail Stop 4561
September 26, 2005
By U.S. Mail and Facsimile to (770) 830-2969
Steven J. Haack
Treasurer
WGNB Corp.
201 Maple Street
P.O. Box 280
Carrollton, Georgia 30117
Re: WGNB Corp.
Form 10-K for Fiscal Year Ended December 31, 2004
Filed March 28, 2005
File No. 000-30805
Dear Mr. Haack:
We have reviewed your filings and have the following
comments.
We have limited our review to the issues we have addressed in our
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 comments are inapplicable or
revisions
are unnecessary. Please be as detailed as necessary in your
explanation. After reviewing this information, we may raise
additional comments.
Please understand that 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 comment or any other aspect
of
our review. Feel free to call us at the telephone numbers listed
at
the end of this letter.
Consolidated Statement of Earnings, page F-4
1. Please explain to us your accounting policy for mortgage
origination fees. In addition, tell us how your classification of
mortgage origination fees as other income is consistent with
paragraph 5 of SFAS 91.
Summary of Significant Accounting Policies
Derivative Instruments and Hedging Activities, page F-11
2. Please advise us as follows with respect to the interest rate
swap
that you have designated as a fair value hedge of your fixed rate
convertible FHLB advances:
* Provide us with and revise future filings to disclose the
information required by paragraph 45 of SFAS 133.
* Identify whether you use the long-haul method, the short-cut
method, or matched terms to assess the effectiveness of this
hedging
strategy.
* Describe how you assess hedge effectiveness and measure hedge
ineffectiveness.
* If you apply the short cut method of assessing hedge
effectiveness,
tell us how you determined that this hedge met the conditions of
paragraph 68 of SFAS 133 to qualify for such treatment.
As appropriate, please amend your filing and respond to
these
comments within 10 business days or tell us when you will provide
us
with a response. Please furnish a cover letter with your
amendment
that keys your response to our comments and provides any requested
information. Detailed cover letters greatly facilitate our
review.
Please understand that we may have additional comments after
reviewing your amendment and response to our comments.
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 all information required under the Securities
Exchange Act of 1934 and that they have provided all information
investors require for an informed investment decision. 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 filing;
* staff comments or changes to disclosure in response to staff
comments 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 comment on your filing.
You may contact Margaret Fitzgerald at (202) 551-3556 or me
at
(202) 551-3426 if you have questions regarding comments on the
financial statements and related matters.
Sincerely,
Angela Jackson
Senior Accountant
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Steven J. Haack
WGNB Corp.
September 26, 2005
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