SEC Company Response from First Federal of Northern Michigan Bancorp, Inc. (CIK 0001128227) — Feb 11, 2005
First Federal of Northern Michigan Bancorp, Inc. (CIK 0001128227)
Date: Feb. 11, 2005 · CIK: 0001128227 · Accession: 0001188112-05-000266
AI Filing Summary & Sentiment
File numbers found in text: 333-121178
Referenced dates: February 9, 2005
Letter
VIA EDGAR Securities and Exchange Commission Division of Corporation Finance 450 Fifth Street, N.W. Washington, D.C. 20549 Attn.: Barry McCarty, Esq. Senior Counsel
RE: FIRST FEDERAL OF NORTHERN MICHIGAN BANCORP INC. (REGISTRATION NO. 333-121178) REGISTRATION STATEMENT ON FORM SB-2
Dear Mr. McCarty:
On behalf of First Federal of Northern Michigan Bancorp, Inc. (the "Company") and in accordance with Rule 101 of Regulation S-T, we are hereby transmitting Pre-effective Amendment No. 3 to the Company's Registration Statement on Form SB-2 (the "Amended SB-2"). Set forth below are the Company's responses to the Staff's comment letter dated February 9, 2005, a copy of which is included in the courtesy copy of the Amended SB-2 forwarded under cover of this letter. The Amended SB-2 has been blacklined to reflect changes from the Amendment No. 2 filing.
1. As discussed with staff, we have revised the disclosure on pages 6 and 7 as requested in the comment.
2. We have clarified on page 8 the use made by the independent appraiser of the after-market performance of the peer institutions, as requested in the comment.
3. We have supplemented page 22 to make clear that management has not set a timetable for the deployment of the proceeds of the offering, as requested in the comment.
4. We have revised and supplemented the disclosure on pages 87 and 88, and on page F-9, in response to the comment. It should be noted that the terms of the Blue Cross/Blue Shield contract are brief; we have disclosed the material terms of the contract.
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Barry McCarty, Esq. Senior Counsel February 11, 2005 Page 2
5. We have supplemented the disclosure on pages 87 and 88 in response to the comment requesting a more-detailed discussion of the insurance agency segment. We also have supplemented the MD&A on pages 30, 32, 33 and 64 to break out, where material, the contribution of the insurance agency segment to the Company's operating results.
6. We have revised and supplemented the disclosure on pages 82, 87, 88, 96, 97, F-14 and F-26 in response to the comment.
We trust the foregoing is responsive to the staff's comments. Please call the undersigned at (202) 274-2011 should you have any questions.
Respectfully,
/s/ Robert B. Pomerenk
Show Raw Text
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(202) 274-2011 rpomerenk@luselaw.com
February 11, 2005
VIA EDGAR
Securities and Exchange Commission
Division of Corporation Finance
450 Fifth Street, N.W.
Washington, D.C. 20549
Attn.: Barry McCarty, Esq.
Senior Counsel
RE: FIRST FEDERAL OF NORTHERN MICHIGAN BANCORP INC.
(REGISTRATION NO. 333-121178)
REGISTRATION STATEMENT ON FORM SB-2
Dear Mr. McCarty:
On behalf of First Federal of Northern Michigan Bancorp, Inc. (the
"Company") and in accordance with Rule 101 of Regulation S-T, we are hereby
transmitting Pre-effective Amendment No. 3 to the Company's Registration
Statement on Form SB-2 (the "Amended SB-2"). Set forth below are the Company's
responses to the Staff's comment letter dated February 9, 2005, a copy of which
is included in the courtesy copy of the Amended SB-2 forwarded under cover of
this letter. The Amended SB-2 has been blacklined to reflect changes from the
Amendment No. 2 filing.
1. As discussed with staff, we have revised the disclosure on pages
6 and 7 as requested in the comment.
2. We have clarified on page 8 the use made by the independent
appraiser of the after-market performance of the peer institutions, as requested
in the comment.
3. We have supplemented page 22 to make clear that management has
not set a timetable for the deployment of the proceeds of the offering, as
requested in the comment.
4. We have revised and supplemented the disclosure on pages 87 and
88, and on page F-9, in response to the comment. It should be noted that the
terms of the Blue Cross/Blue Shield contract are brief; we have disclosed the
material terms of the contract.
<PAGE>
Barry McCarty, Esq.
Senior Counsel
February 11, 2005
Page 2
5. We have supplemented the disclosure on pages 87 and 88 in
response to the comment requesting a more-detailed discussion of the insurance
agency segment. We also have supplemented the MD&A on pages 30, 32, 33 and 64 to
break out, where material, the contribution of the insurance agency segment to
the Company's operating results.
6. We have revised and supplemented the disclosure on pages 82, 87,
88, 96, 97, F-14 and F-26 in response to the comment.
We trust the foregoing is responsive to the staff's comments. Please
call the undersigned at (202) 274-2011 should you have any questions.
Respectfully,
/s/ Robert B. Pomerenk
Robert B. Pomerenk
Enclosures
cc: David Lyon, Esq.
Rebekah Moore, CPA
Paul Cline, CPA
Martin A. Thomson, President and
Chief Executive Officer
Eric Luse, Esq.
Steve Lanter, Esq.
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