SEC Comment Letter 0000000000-23-013811 to Hilltop Holdings Inc. (HTH) (CIK 0001265131) (HTH)
Hilltop Holdings Inc. (HTH) (CIK 0001265131)
Date: Dec. 19, 2023 · CIK: 0001265131 · Accession: 0000000000-23-013811
AI Filing Summary & Sentiment
File numbers found in text: 001-31987
Letter
United States securities and exchange commission logo December 19, 2023 William B. Furr Chief Financial Officer Hilltop Holdings Inc. 6565 Hillcrest Avenue Dallas, TX 75205 Re:Hilltop Holdings Inc. Form 10-K for Fiscal Year Ended December 31, 2022 Filed February 17, 2023 Form 10-Q for the Quarterly Period Ended September 30, 2023 Filed October 23, 2023 File No. 001-31987 Dear William B. Furr: We have limited our review of your filing to the financial statements and related disclosures 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. After reviewing your response to this letter, we may have additional comments. Form 10-Q for the Quarterly Period Ended September 30, 2023 Management's Discussion and Analysis of Financial Condition and Results of Operations Loan Portfolio, page 73 1.We note the tabular disclosure on page 73 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 disaggregate the composition of your CRE loan portfolio by borrower type (e.g., by office, hotel, multifamily, etc.), geographic concentrations and other characteristics (e.g., current weighted average and/or range of loan-to-value ratios, occupancy rates, etc.) material to an investor’s understanding of your CRE loan portfolio. 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.
FirstName LastNameWilliam B. Furr Comapany NameHilltop Holdings Inc. December 19, 2023 Page 2 FirstName LastName William B. Furr Hilltop Holdings Inc. December 19, 2023 Page 2 In closing, we remind you that the company and its management are responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the staff. Please contact Jee Yeon Ahn at 202-551-3673 or Lory Empie at 202-551-3714 with any questions. Sincerely, Division of Corporation Finance Office of Finance
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United States securities and exchange commission logo
December 19, 2023
William B. Furr
Chief Financial Officer
Hilltop Holdings Inc.
6565 Hillcrest Avenue
Dallas, TX 75205
Re:Hilltop Holdings Inc.
Form 10-K for Fiscal Year Ended December 31, 2022
Filed February 17, 2023
Form 10-Q for the Quarterly Period Ended September 30, 2023
Filed October 23, 2023
File No. 001-31987
Dear William B. Furr:
We have limited our review of your filing to the financial statements and related
disclosures 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.
After reviewing your response to this letter, we may have additional comments.
Form 10-Q for the Quarterly Period Ended September 30, 2023
Management's Discussion and Analysis of Financial Condition and Results of Operations
Loan Portfolio, page 73
1.We note the tabular disclosure on page 73 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
disaggregate the composition of your CRE loan portfolio by borrower type (e.g., by office,
hotel, multifamily, etc.), geographic concentrations and other characteristics (e.g., current
weighted average and/or range of loan-to-value ratios, occupancy rates, etc.) material to
an investor’s understanding of your CRE loan portfolio. 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.
FirstName LastNameWilliam B. Furr
Comapany NameHilltop Holdings Inc.
December 19, 2023 Page 2
FirstName LastName
William B. Furr
Hilltop Holdings Inc.
December 19, 2023
Page 2
In closing, we remind you that the company and its management are responsible for the
accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or
absence of action by the staff.
Please contact Jee Yeon Ahn at 202-551-3673 or Lory Empie at 202-551-3714 with any
questions.
Sincerely,
Division of Corporation Finance
Office of Finance