SEC Comment Letter for Bancorp, Inc. (TBBK) (CIK 0001295401) (TBBK) — Jul 24, 2009
Bancorp, Inc. (TBBK) (CIK 0001295401)
Date: July 24, 2009 · CIK: 0001295401 · Accession: 0000000000-09-039403
AI Filing Summary & Sentiment
Reasoning
Letter
UNITED STATES SECURmeS AND EXCHANGE COMMISSION WASHINGTON, D.C. 20549 May 6, 2009 Mail Stop 4561 By u.s. Mail andfacsi1ne to (301) 791-5609 -Mar F. Ega Chief Finia Offcer The BnnCQl" Inc. 11 409 SilveiideRoa Wilmingtn, DE 19809 RI!: . Thl! B:m~(lrp Int. Form l()Kfor the period ended December 31, 200 File No. (¡51/ll8 Dea Mr. Egan: We have reviewed th aboe referced filig and have the following comments. We have limited our review to onl your finaial statents and rela-id disclosure and do not inted to expand our reew to other poions of your documents. Plea be as detled as nec in your expliuon. In ou CQmments, we may ask you to provide us with informtion so we may better understad your dislosure. Afer reviewing this infortion, we may rase addional comments. Plea undersd that the purse of our reew pres is to asis you in your CQmpliance with the applicable disclosu requirements and to cihanc-e theoveral disclosure in your fiing. We look forwar to working with you in these repets. We weloo any queions you ma have about our commen or any other aspect of our review. Feel fr to cal us at the telephone numbers listed at the end of ths letter. * * '" *
Mr. Marin F. Egan The BanCQrp, Inc. May 6, 2009 Pa¡ie 2 of3 Form IO-K for th Year Ended Deceber 31. 2008 Item 8. Finaial Statements an Sllplementa Data Notes to Con.t(lidated Finacial Stateents Note D - Investment Securties. p~e 64 I. We note the signcat unize losse related to your beld-to-matuty debt secties at Deceber 31, 2008. We have the followig CQmments: . pleae provide us a ftl detaled analyi,is of thes seurties' impainent as of Dember 3 i, 2008 tht identifies all availale evidece, explai the relative signficace of eah piece of evidence. an identifes the pnma evidence on whieh you rely to support a reali7..le vaue equa to or gr than the cang value of the inW'nt. Speificaly tell us if you consider al avalable evidence, includig inortion reived afr yea end, afting the project ca flows as of the penod en. We may hae fuer comment bad on your reponse; and · plea provide us an C(nsder disclosing in all futu filigs, a tåble detili the following inormaton for your trt prefer seurties: dea na, single-issuer or poled, clas book vaue, fai value, umze gan/oss. cret rnngs niunher of bans in issuance, defuls and defaults as a percetage of collatera, and excess subonition after tang into aecunt your be estimates of futur interest defèrrs and defats. Note L - Income Taxes. ~e 71 2. Pleae tenus how you determ th a valuation allowace was not nesa for deferrd ta asts. Speifcaly detal th positive and negative evidence us to support your decsion under pargrphs 23-24 of SPAS 109 (reer also paph 103). *""" Pleas send us yó-ir respnse to these comments with 10 business days or tell us when you will provide US with a reponse. Plea fush a CQve letter keyg your repons to our CQmments an provide any requested supplementa informtion. Plea tile your repons letter on EDAR. Please under that we may have additional cOmmts af reviewin your respose to our comments We ur all pens who are responsible fòr the accury and adequacy of the disclosur in the fiing to be cen tht the fiin includes all infurmaton reuire under the Securties Exchimge Act of 1934 an that they have provided all inormaton invesors ./
). Mr. Mar F. Ega Th Bacorp,Irtc. May 6, 200 Pag 3 00 reuir tor an inormed invesent decision. Since the compay and its magement are in pos.'lCssion of all fats relatig to a cmnpay's disclosur they ar reponsible for the accuracy and adua of th dÍsclos they have made. In CQmition with repondig to our comments. plea provide, in .writi, a statement frm the compay iicknwledgig tht: . the compay is reponsible for the adequacy and acurcy of the disclosure in thefig; . staff comments or chages to disclosure in respns to sta comments do not forelose the Commsion frm ting any action with ret to th filing; and . the compay may not asrt stff comments as a defense in any prong initiat by the Commisson or any persn under th feder seinties laws. of the United Staes ø' In additon, pleas be adv~d that th Division of Enforcement ha acess to all informtion you provide to the ¡¡taff of the Division of Corpmtíon Finance in our review of your fiing orin rens to our comments on your ming. Y oumay cotact Dave Ir Revieiing Accountant, at (202) 551-3321 or me at (202) 551-3474 if you have quons. Sinceely, Sharn M. Blume Asstat Chief Accuntat
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UNITED STATES SECURmeS AND EXCHANGE COMMISSION WASHINGTON, D.C. 20549 May 6, 2009 Mail Stop 4561 By u.s. Mail andfacsi1ne to (301) 791-5609 -Mar F. Ega Chief Finia Offcer The BnnCQl" Inc. 11 409 SilveiideRoa Wilmingtn, DE 19809 RI!: . Thl! B:m~(lrp Int. Form l()Kfor the period ended December 31, 200 File No. (¡51/ll8 Dea Mr. Egan: We have reviewed th aboe referced filig and have the following comments. We have limited our review to onl your finaial statents and rela-id disclosure and do not inted to expand our reew to other poions of your documents. Plea be as detled as nec in your expliuon. In ou CQmments, we may ask you to provide us with informtion so we may better understad your dislosure. Afer reviewing this infortion, we may rase addional comments. Plea undersd that the purse of our reew pres is to asis you in your CQmpliance with the applicable disclosu requirements and to cihanc-e theoveral disclosure in your fiing. We look forwar to working with you in these repets. We weloo any queions you ma have about our commen or any other aspect of our review. Feel fr to cal us at the telephone numbers listed at the end of ths letter. * * '" * Mr. Marin F. Egan The BanCQrp, Inc. May 6, 2009 Pa¡ie 2 of3 Form IO-K for th Year Ended Deceber 31. 2008 Item 8. Finaial Statements an Sllplementa Data Notes to Con.t(lidated Finacial Stateents Note D - Investment Securties. p~e 64 I. We note the signcat unize losse related to your beld-to-matuty debt secties at Deceber 31, 2008. We have the followig CQmments: . pleae provide us a ftl detaled analyi,is of thes seurties' impainent as of Dember 3 i, 2008 tht identifies all availale evidece, explai the relative signficace of eah piece of evidence. an identifes the pnma evidence on whieh you rely to support a reali7..le vaue equa to or gr than the cang value of the inW'nt. Speificaly tell us if you consider al avalable evidence, includig inortion reived afr yea end, afting the project ca flows as of the penod en. We may hae fuer comment bad on your reponse; and · plea provide us an C(nsder disclosing in all futu filigs, a tåble detili the following inormaton for your trt prefer seurties: dea na, single-issuer or poled, clas book vaue, fai value, umze gan/oss. cret rnngs niunher of bans in issuance, defuls and defaults as a percetage of collatera, and excess subonition after tang into aecunt your be estimates of futur interest defèrrs and defats. Note L - Income Taxes. ~e 71 2. Pleae tenus how you determ th a valuation allowace was not nesa for deferrd ta asts. Speifcaly detal th positive and negative evidence us to support your decsion under pargrphs 23-24 of SPAS 109 (reer also paph 103). *""" Pleas send us yó-ir respnse to these comments with 10 business days or tell us when you will provide US with a reponse. Plea fush a CQve letter keyg your repons to our CQmments an provide any requested supplementa informtion. Plea tile your repons letter on EDAR. Please under that we may have additional cOmmts af reviewin your respose to our comments We ur all pens who are responsible fòr the accury and adequacy of the disclosur in the fiing to be cen tht the fiin includes all infurmaton reuire under the Securties Exchimge Act of 1934 an that they have provided all inormaton invesors 2 ./ ). Mr. Mar F. Ega Th Bacorp,Irtc. May 6, 200 Pag 3 00 reuir tor an inormed invesent decision. Since the compay and its magement are in pos.'lCssion of all fats relatig to a cmnpay's disclosur they ar reponsible for the accuracy and adua of th dÍsclos they have made. In CQmition with repondig to our comments. plea provide, in .writi, a statement frm the compay iicknwledgig tht: . the compay is reponsible for the adequacy and acurcy of the disclosure in thefig; . staff comments or chages to disclosure in respns to sta comments do not forelose the Commsion frm ting any action with ret to th filing; and . the compay may not asrt stff comments as a defense in any prong initiat by the Commisson or any persn under th feder seinties laws. of the United Staes ø' In additon, pleas be adv~d that th Division of Enforcement ha acess to all informtion you provide to the ¡¡taff of the Division of Corpmtíon Finance in our review of your fiing orin rens to our comments on your ming. Y oumay cotact Dave Ir Revieiing Accountant, at (202) 551-3321 or me at (202) 551-3474 if you have quons. Sinceely, Sharn M. Blume Asstat Chief Accuntat 3