SEC Comment Letter for WEST BANCORPORATION INC (WTBA) (CIK 0001166928) (WTBA) — Sep 5, 2013
WEST BANCORPORATION INC (WTBA) (CIK 0001166928)
Date: Sept. 5, 2013 · CIK: 0001166928 · Accession: 0000000000-13-048803
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September 5, 2013
Via E -mail
Doug Gulling
Chief Financial Officer
West Bancorporation, Inc.
1601 22nd Street
West Des Moines , IA 50266
Re: West Bancorporation, Inc.
Form 10 -K for the period ended December 31, 2012
Filed March 6, 2013
Form 10 -Q for the period ended June 30, 2013
Filed July 26, 2013
File No. 00 0-49677
Dear M r. Gulling :
We have reviewed your filing s and have the following comments. In some of our
comments, we may ask you to provide us with information so we may better understand your
disclosure.
Please respond to this letter within ten business days by providing the requested
information or by advi sing us when you will provide the requested response. If you do not
believe our comments apply to your facts and circumstances please tell us why in your response.
After reviewing the information you provide in response to these comments, we may
have additional comments.
June 30, 2013 Form 10 -Q
Note 7. Fair Value Measurements, page 24
1. Please revise future filings to provide quantitative information about the significant
unobservable inputs used in the fair value measurement for each class of your r ecurring
and nonrecurring measurements categorized within level 3. Refer to ASC 820 -10-50-2-
bbb for guidance and ASC 820 -10-55-103 for example disclosure.
Doug Gulling
West Bancorporation, Inc.
September 5, 2013
Page 2
Management’s Discussion and Analysis of Financial Condition and Results of Operations –
Provision for Loan Losses and the Related Allowance for Loan Losses, page 37
2. We observe from Note 4 on page 22 that the allowance for loan losses collectively
evaluated for impairment as a percentage of loans collectively evaluated for impairment
increased from De cember 31, 2012 to June 30, 2013 while we note improving trends in
credit quality. Please tell us in detail and revise future filing s to comprehensively discuss
the reasons for this trend and its relationship with observed changes in the credit quality
of yo ur collectively evaluated portfolio for each period presented .
Please be as specific and detailed as needed to provide an investor with a clear
understanding of the observed change in the credit quality of your collectively evaluated
loan portfolio and how this change, as well as other key drivers, impacted your
colle ctively evaluated allowance for loan losses. For instance, discuss trends in the types
of loans and related credit risk included in this portfolio, trends in historical losses
incorporated in your allowance methodology, and trends observed in specific qua litative
factors.
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 Exchange Act of
1934 and all applicable Exchange A ct 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 responding to our comments, please provide a written 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.
You may contact Mike Volley at 202-551-3437 or me at 202-551-3423 if you have
questions .
Sincerely,
/s/ Amit Pande
Amit Pande
Accounting Branch Chief