SEC Comment Letter for NORTHRIM BANCORP INC (NRIM) (CIK 0001163370) (NRIM) — Aug 17, 2016
NORTHRIM BANCORP INC (NRIM) (CIK 0001163370)
Date: Aug. 17, 2016 · CIK: 0001163370 · Accession: 0000000000-16-088976
AI Filing Summary & Sentiment
Reasoning
Referenced dates: April 29, 2016
Letter
August 17 , 2016 Mail Stop 4720 Via E -mail Latosha M. Frye Chief Financial Officer Northrim Bancorp, Inc. 3111 C Street Anchorage, Alaska 99503
Re: Northrim Bancorp, Inc. Form 10-K for the Fiscal Year Ended December 31, 2015 Filed March 11, 2016 File No. 000 -33501
Dear Ms. Frye :
We have reviewed your May 20, July 1 , and July 11, 2016 responses to our comment letter and have the following comment . In our comment , we may ask you to provide us with information so we may better understand your disclosure.
Please respond to this comment within ten busine ss days by providing the requested information or advis e us as soon as possible when you will respond. If you do not belie ve our comment applies to your facts and circumstances, please tell us why in your response.
After reviewing your response to this comment , we may have additional comments.
Form 10 -K for the Fiscal Year Ended December 31, 2015
Item 8. Financial Sta tements and Supplementary Data
Note 2 – Business Combinations, page 70
Residential Mortgage, page 72
1. We note your responses to prior comment 2 to our letter dated April 29, 2016 and object to your view that the contingent payments related to the acquisition of RML should be accounted for as contingent consideration instead of compensation. Please provide us with your materiality analysis pursuant to ASC 250 -10-S99 as of December 31, 2014 and updated through your most recent quarter end that reflects the impact of recognizing the contingent payments as compensation. To the extent you conclude that this error is not material to your
Latosha M. Frye Northrim Bancorp, Inc. August 17, 2016 Page 2
historical financial statemen ts, please describe how you plan to correct this error in future filings and describe the type s of disclosure s you would plan to make .
You may contact Michelle Miller at 202-551-3368 or me at 202-551-3512 with any questions.
Sincerely,
/s/ Stephanie L. Sullivan
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August 17 , 2016 Mail Stop 4720 Via E -mail Latosha M. Frye Chief Financial Officer Northrim Bancorp, Inc. 3111 C Street Anchorage, Alaska 99503 Re: Northrim Bancorp, Inc. Form 10-K for the Fiscal Year Ended December 31, 2015 Filed March 11, 2016 File No. 000 -33501 Dear Ms. Frye : We have reviewed your May 20, July 1 , and July 11, 2016 responses to our comment letter and have the following comment . In our comment , we may ask you to provide us with information so we may better understand your disclosure. Please respond to this comment within ten busine ss days by providing the requested information or advis e us as soon as possible when you will respond. If you do not belie ve our comment applies to your facts and circumstances, please tell us why in your response. After reviewing your response to this comment , we may have additional comments. Form 10 -K for the Fiscal Year Ended December 31, 2015 Item 8. Financial Sta tements and Supplementary Data Note 2 – Business Combinations, page 70 Residential Mortgage, page 72 1. We note your responses to prior comment 2 to our letter dated April 29, 2016 and object to your view that the contingent payments related to the acquisition of RML should be accounted for as contingent consideration instead of compensation. Please provide us with your materiality analysis pursuant to ASC 250 -10-S99 as of December 31, 2014 and updated through your most recent quarter end that reflects the impact of recognizing the contingent payments as compensation. To the extent you conclude that this error is not material to your Latosha M. Frye Northrim Bancorp, Inc. August 17, 2016 Page 2 historical financial statemen ts, please describe how you plan to correct this error in future filings and describe the type s of disclosure s you would plan to make . You may contact Michelle Miller at 202-551-3368 or me at 202-551-3512 with any questions. Sincerely, /s/ Stephanie L. Sullivan Stephanie L. Sullivan Senior Assistant Chief Accountant