SEC Comment Letter 0000000000-24-007084 to OptimumBank Holdings, Inc. (OPHC) (CIK 0001288855) (OPHC)
OptimumBank Holdings, Inc. (OPHC) (CIK 0001288855)
Date: June 21, 2024 · CIK: 0001288855 · Accession: 0000000000-24-007084
AI Filing Summary & Sentiment
File numbers found in text: 333-278970
Letter
United States securities and exchange commission logo June 21, 2024 Timothy Terry Principal Executive Officer OptimumBank Holdings, Inc. 2929 East Commercial Boulevard, Suite 303 Ft. Lauderdale, Florida 33308 Re:OptimumBank Holdings, Inc. Amendment No. 1 to Registration Statement on Form S-3 Filed June 4, 2024 File No. 333-278970 Dear Timothy Terry: We have reviewed your amended registration statement and have the following comments. Please respond to this letter by amending your registration statement and providing the requested information. If you do not believe a comment applies to your facts and circumstances or do not believe an amendment is appropriate, please tell us why in your response. After reviewing any amendment to your registration statement and the information you provide in response to this letter, we may have additional comments. Unless we note otherwise, any references to prior comments are to comments in our May 17, 2024 letter. Amendment No. 1 to Form S-3 A significant portion of our loan portfolio is secured by real estate, page 9 1.We note your response to prior comment 3. Please revise your disclosure to discuss the current real estate environment and economy in which you are operating, and material adverse effects such environment or economy has had on your business and results of operations, if any. We have a large concentration of commercial real estate loans, page 9 2.We note your discussion of the risks associated with your commercial real estate portfolio. To provide investors with context on your exposure to different types of commercial real estate loans, please disclose the subclasses by property type, the percentage concentration in each subclass property type, any lending limits per subclass and any concentration among your borrowers.
FirstName LastNameTimothy Terry Comapany NameOptimumBank Holdings, Inc. June 21, 2024 Page 2 FirstName LastName Timothy Terry OptimumBank Holdings, Inc. June 21, 2024 Page 2
Our regulators are focused on commercial real estate lending, page 10 3.We note that you state that regulators may require banks to maintain elevated levels of capital or liquidity due to commercial real estate loan concentrations. Please clarify if OptimumBank is subject to any additional capital requirements as a result of its portfolio. Please contact Madeleine Joy Mateo at 202-551-3465 or Susan Block at 202-551-3210 with any other questions. Sincerely, Division of Corporation Finance Office of Finance cc: Christina Ahrens, Esq.
Show Raw Text
United States securities and exchange commission logo
June 21, 2024
Timothy Terry
Principal Executive Officer
OptimumBank Holdings, Inc.
2929 East Commercial Boulevard, Suite 303
Ft. Lauderdale, Florida 33308
Re:OptimumBank Holdings, Inc.
Amendment No. 1 to Registration Statement on Form S-3
Filed June 4, 2024
File No. 333-278970
Dear Timothy Terry:
We have reviewed your amended registration statement and have the following
comments.
Please respond to this letter by amending your registration statement and providing the
requested information. If you do not believe a comment applies to your facts and circumstances
or do not believe an amendment is appropriate, please tell us why in your response.
After reviewing any amendment to your registration statement and the information you
provide in response to this letter, we may have additional comments. Unless we note otherwise,
any references to prior comments are to comments in our May 17, 2024 letter.
Amendment No. 1 to Form S-3
A significant portion of our loan portfolio is secured by real estate, page 9
1.We note your response to prior comment 3. Please revise your disclosure to discuss the
current real estate environment and economy in which you are operating, and material
adverse effects such environment or economy has had on your business and results of
operations, if any.
We have a large concentration of commercial real estate loans, page 9
2.We note your discussion of the risks associated with your commercial real estate
portfolio. To provide investors with context on your exposure to different types of
commercial real estate loans, please disclose the subclasses by property type, the
percentage concentration in each subclass property type, any lending limits per subclass
and any concentration among your borrowers.
FirstName LastNameTimothy Terry
Comapany NameOptimumBank Holdings, Inc.
June 21, 2024 Page 2
FirstName LastName
Timothy Terry
OptimumBank Holdings, Inc.
June 21, 2024
Page 2
Our regulators are focused on commercial real estate lending, page 10
3.We note that you state that regulators may require banks to maintain elevated levels of
capital or liquidity due to commercial real estate loan concentrations. Please clarify if
OptimumBank is subject to any additional capital requirements as a result of its portfolio.
Please contact Madeleine Joy Mateo at 202-551-3465 or Susan Block at 202-551-3210
with any other questions.
Sincerely,
Division of Corporation Finance
Office of Finance
cc: Christina Ahrens, Esq.