SEC Comment Letter 0000000000-24-001077 to WESTERN ALLIANCE BANCORPORATION (WAL, WAL-PA) (CIK 0001212545) (WAL)
WESTERN ALLIANCE BANCORPORATION (WAL, WAL-PA) (CIK 0001212545)
Date: Jan. 26, 2024 · CIK: 0001212545 · Accession: 0000000000-24-001077
AI Filing Summary & Sentiment
File numbers found in text: 001-32550
Letter
United States securities and exchange commission logo January 26, 2024 Dale Gibbons Chief Financial Officer Western Alliance Bancorporation One E. Washington Street, Suite 1400 Phoenix, AZ 85004 Re:Western Alliance Bancorporation Form 10-K for the Fiscal Year Ended December 31, 2022 Form 10-Q for the Quarterly Period Ended September 30, 2023 Response Dated October 10, 2023 File No. 001-32550 Dear Dale Gibbons: We have reviewed your October 10, 2023 response to our comment letter and have the following comment. Please respond to this letter within ten business days by providing the requested information or advise us as soon as possible when you will respond. If you do not believe a comment applies to your facts and circumstances, please tell us why in your response.
Form 10-Q filed October 31, 2023 Concentration of Lending Activities, page 75 1.We note the tabular disclosure and discussion on page 75 detailing the composition of your gross loan portfolio, which includes commercial real estate (“CRE”). Given the significance of CRE in your total loan portfolio, please revise your disclosures, in future filings, to further discuss other CRE characteristics (e.g., current weighted average and/or range of loan-to-value ratios, updated vacancy rates, etc.), if any. In addition, revise to describe the specific details of any risk management policies, procedures or other actions undertaken by management in response to the current environment. Please contact Lory Empie at 202-551-3714 or John Nolan at 202-551-3492 if you have questions regarding comments on the financial statements and related matters. Please contact John Stickel at 202-551-3324 or James Lopez at 202-551-3536 with any other questions.
FirstName LastNameDale Gibbons Comapany NameWestern Alliance Bancorporation January 26, 2024 Page 2 FirstName LastName Dale Gibbons Western Alliance Bancorporation January 26, 2024 Page 2 Sincerely, Division of Corporation Finance Office of Finance
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United States securities and exchange commission logo
January 26, 2024
Dale Gibbons
Chief Financial Officer
Western Alliance Bancorporation
One E. Washington Street, Suite 1400
Phoenix, AZ 85004
Re:Western Alliance Bancorporation
Form 10-K for the Fiscal Year Ended December 31, 2022
Form 10-Q for the Quarterly Period Ended September 30, 2023
Response Dated October 10, 2023
File No. 001-32550
Dear Dale Gibbons:
We have reviewed your October 10, 2023 response to our comment letter and have the
following comment.
Please respond to this letter within ten business days by providing the requested
information or advise us as soon as possible when you will respond. If you do not believe a
comment applies to your facts and circumstances, please tell us why in your response.
Form 10-Q filed October 31, 2023
Concentration of Lending Activities, page 75
1.We note the tabular disclosure and discussion on page 75 detailing the composition of
your gross loan portfolio, which includes commercial real estate (“CRE”). Given the
significance of CRE in your total loan portfolio, please revise your disclosures, in future
filings, to further discuss other CRE characteristics (e.g., current weighted average and/or
range of loan-to-value ratios, updated vacancy rates, etc.), if any. In addition, revise to
describe the specific details of any risk management policies, procedures or other actions
undertaken by management in response to the current environment.
Please contact Lory Empie at 202-551-3714 or John Nolan at 202-551-3492 if you have
questions regarding comments on the financial statements and related matters. Please contact
John Stickel at 202-551-3324 or James Lopez at 202-551-3536 with any other questions.
FirstName LastNameDale Gibbons
Comapany NameWestern Alliance Bancorporation
January 26, 2024 Page 2
FirstName LastName
Dale Gibbons
Western Alliance Bancorporation
January 26, 2024
Page 2
Sincerely,
Division of Corporation Finance
Office of Finance