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SEC Company Response from CITIZENS FIRST BANCORP INC (CIK 0001127442) — Oct 5, 2005

CITIZENS FIRST BANCORP INC (CIK 0001127442)
Date: Oct. 5, 2005 · CIK: 0001127442 · Accession: 0000950124-05-005642

AI Filing Summary & Sentiment

File numbers found in text: 000-32041

Referenced dates: September 16, 2005

Date
October 4, 2005
Author
Not clearly detected
Form
CORRESP
Company
CITIZENS FIRST BANCORP INC (CIK 0001127442)

Letter

VIA EDGAR AND COURIER Division of Corporation Finance Re: Citizens First Bancorp, Inc. (the “Company”) Forms 10-K for the Fiscal Year Ended December 31, 2004 File No. 000-32041

Dear Mr. Walker:

This letter is provided in connection with the review letters from your office dated September 2, 2005 and September 22, 2005 regarding the filings referenced above. The response items indicated below are keyed exactly to the item numbers provided in your letter. Please note that comments in this letter should be reviewed in conjunction with our letter dated September 16, 2005.

Comment No. 1:

The Freddie Mac equity preferred stock investment yield is based on the Twelve month LIBOR rate less 20 basis points and resets on a yearly basis on April 1st. Additionally, the security is DRD eligible, meaning that 70% of the dividend is tax exempt to the Bank.

1 of 5

12 Month Libor:

Ask Yield 4.24000 High on 05/13/00 7.50125 Average 3.32837 Low on 06/30/03 1.19000

Australia 61 2 9777 8600 Brazil 5511 3048 4500 Europe 44 20 7330 7500 Germany 49 69 920410 Hong Kong 852 2977 6000 Japan 81 3 3201 8900 Singapore 65 6212 1000 U.S. 1 212 318 2000 G263-849-3 30-Sep-05 16:37:43

As depicted in the graph above, interest rates on twelve month LIBOR (the index) have continued to rise from the record lows in 2003 and 2004. Rates are heading back towards 2001 levels, similar levels when the security was purchased.

2 of 5

As shown in the table below, the index on this security repriced from 1.14% to 3.64% on April 1, 2005, or slightly higher than management expected.

Floating Rate Index History

Annual US LIBOR

Australia 61 2 9777 8600 Brazil 5511 3048 4500 Europe 44 20 7330 7500 Germany 49 69 920410 Hong Kong 852 2977 6000 Japan 81 3 3201 8900 Singapore 65 6212 1000 U.S. 1 212 318 2000 G263-849-1 28-Sep-05 14:20:29

The market price of the floating rate equity preferred stock investment in Freddie Mac beginning September 30, 2004 and quarterly through September 30, 2005 was $39.00, $38.00, $42.50, $41.30 and $42.50 respectively, as depicted in the following graph.

3 of 5

EXCH/Md/USD Price 41.000 High on 01/06/04 49.500 Average 41.471 Low on 10/18/04 36.250

Australia 61 2 9777 8600 Brazil 5511 3048 4500 Europe 44 20 7330 7500 Germany 49 69 920410 Hong Kong 852 2977 6000 Japan 81 3 3201 8900 Singapore 65 6212 1000 U.S. 1 212 318 2000 G263-849-1 28-Sep-05 12:41:18

The following table represents the unrealized loss position, in thousands, for less than 12 months and 12 months or more for this stock investment.

Unrealized

Unrealized

Amortized

Unrealized

Loss

Loss

Carrying

Cost

Gain

> 12 Months

< 12 Months

Value

September 30, 2004

$ 5,002

—

$

—

$ 4,415

December 31, 2004

5,002

—

1,117

—

3,885

March 31, 2005

5,002

—

—

4,247

June 30, 2005

5,002

—

—

4,205

September 30, 2005

5,002

—

—

4,125

Management continues to provide updates to ALCO, the Board of Directors, our auditors, and the Audit Committee via news articles and other pertinent date to support our analysis.

4 of 5

We would appreciate receiving any additional comments which the Staff may have at your earliest possible convenience. Please direct any further comments to the undersigned or Michael D. Luna at (810) 990-1550.

Very truly yours,
CITIZENS FIRST BANCORP, INC.

Show Raw Text
CORRESP
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filename1.htm

corresp

October 4, 2005

VIA EDGAR AND COURIER

Mr. Donald Walker

Senior Assistant and Chief Accountant

Division of Corporation Finance

U.S. Securities and Exchange Commission

450 Fifth Street, N.W.

Mail Stop 4561

Washington, DC 20549

    Re:

    Citizens First Bancorp, Inc. (the “Company”)

    Forms 10-K for the Fiscal Year Ended December 31, 2004

    File No. 000-32041

Dear Mr. Walker:

     This letter is provided in connection with the review letters from your office dated September
2, 2005 and September 22, 2005 regarding the filings referenced above. The response items
indicated below are keyed exactly to the item numbers provided in your letter. Please note that
comments in this letter should be reviewed in conjunction with our letter dated September 16, 2005.

Comment No. 1:

     The Freddie Mac equity preferred stock investment yield is based on the Twelve month LIBOR rate
less 20 basis points and resets on a yearly basis on April 1st. Additionally, the
security is DRD eligible, meaning that 70% of the dividend is tax exempt to the Bank.

1 of 5

12 Month Libor:

Ask Yield 4.24000 High on 05/13/00 7.50125 Average 3.32837 Low on 06/30/03 1.19000

Australia 61 2 9777 8600 Brazil 5511 3048 4500 Europe 44 20 7330 7500 Germany 49 69 920410
Hong Kong 852 2977 6000 Japan 81 3 3201 8900 Singapore 65 6212 1000 U.S. 1 212 318 2000
G263-849-3 30-Sep-05 16:37:43

As depicted in the graph above, interest rates on twelve month LIBOR (the index) have continued to
rise from the record lows in 2003 and 2004. Rates are heading back towards 2001 levels, similar
levels when the security was purchased.

2 of 5

As shown in the table below, the index on this security repriced from 1.14% to 3.64% on April 1,
2005, or slightly higher than management expected.

Floating Rate Index History

Annual US LIBOR

Australia 61 2 9777 8600 Brazil 5511 3048 4500 Europe 44 20 7330 7500 Germany 49 69 920410
Hong Kong 852 2977 6000 Japan 81 3 3201 8900 Singapore 65 6212 1000 U.S. 1 212 318 2000
G263-849-1 28-Sep-05 14:20:29

The market price of the floating rate equity preferred stock investment in Freddie Mac
beginning September 30, 2004 and quarterly through September 30, 2005 was $39.00, $38.00,
$42.50, $41.30 and $42.50 respectively, as depicted in the following graph.

3 of 5

EXCH/Md/USD Price 41.000 High on 01/06/04 49.500 Average 41.471 Low on 10/18/04 36.250

Australia 61 2 9777 8600 Brazil 5511 3048 4500 Europe 44 20 7330 7500 Germany 49 69 920410
Hong Kong 852 2977 6000 Japan 81 3 3201 8900 Singapore 65 6212 1000 U.S. 1 212 318 2000
G263-849-1 28-Sep-05 12:41:18

The following table represents the unrealized loss position, in thousands, for less than 12 months
and 12 months or more for this stock investment.

    Unrealized

    Unrealized

    Amortized

    Unrealized

    Loss

    Loss

    Carrying

    Cost

    Gain

    > 12 Months

    < 12 Months

    Value

    September 30, 2004

    $
    5,002

    —

    $
    587

    —

    $
    4,415

    December 31, 2004

    5,002

    —

    1,117

    —

    3,885

    March 31, 2005

    5,002

    —

    755

    —

    4,247

    June 30, 2005

    5,002

    —

    797

    —

    4,205

    September 30, 2005

    5,002

    —

    877

    —

    4,125

     Management continues to provide updates to ALCO, the Board of Directors, our auditors, and the
Audit Committee via news articles and other pertinent date to support our analysis.

4 of 5

     We would appreciate receiving any additional comments which the Staff may have at your
earliest possible convenience. Please direct any further comments to the undersigned or Michael D.
Luna at (810) 990-1550.

Very truly yours,

CITIZENS FIRST BANCORP, INC.

/s/ Timothy D. Regan

Chief Financial Officer

    cc:

    Marshall J. Campbell, Citizens First Bancorp, Inc.

    Christopher A. Kellerman, Chairman, Audit Committee, Citizens First Bancorp, Inc.

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