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SEC Company Response from Partners Financial CORP (CIK 0001306352) — Jul 11, 2005

Partners Financial CORP (CIK 0001306352)
Date: July 11, 2005 · CIK: 0001306352 · Accession: 0001193125-05-140334

AI Filing Summary & Sentiment

File numbers found in text: 333-120068

Date
July 11, 2005
Author
PARTNERS FINANCIAL CORPORATION
Form
CORRESP
Company
Partners Financial CORP (CIK 0001306352)

Letter

Acceleration Request

PARTNERS FINANCIAL CORPORATION

1575 Pine Ridge Road, Suite 15

Naples, Florida 34109

July 11, 2005

VIA EDGAR AND HAND DELIVERY

Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

Attention: Christian Windsor

Re: Partners Financial Corporation

Registration Statement on Form SB-2 (File No. 333-120068)

Ladies and Gentlemen:

Pursuant to Rule 461 of the General Rules and Regulations under the Securities Act of 1933, as amended, Partners Financial Corporation hereby requests that the Commission accelerate the effective date of post-effective amendment number two to the above-referenced Registration Statement and declare such post-effective amendment effective as of July 11, 2005 at 10:00 a.m., Washington, D.C. time, or as soon thereafter as possible. Partners Financial Corporation also requests the Commission to confirm such effective date and time in writing.

Partners Financial Corporation hereby acknowledges that:

•

Should the Commission or the staff, acting pursuant to delegated authority, declare the filing effective, it does not foreclose the Commission from taking any action with respect to the filing;

•

The action of the Commission or the staff, acting pursuant to delegated authority, in declaring the filing effective, does not relieve Partners Financial Corporation from its full responsibility for the adequacy and accuracy of the disclosure in the filing; and

•

Partners Financial Corporation may not assert this action as defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.

Very truly yours,
PARTNERS FINANCIAL CORPORATION

Show Raw Text
CORRESP
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filename1.htm

Acceleration Request

 PARTNERS FINANCIAL CORPORATION

 1575 Pine Ridge Road, Suite 15

 Naples, Florida 34109

 July 11, 2005

 VIA EDGAR AND HAND DELIVERY

 Securities and Exchange Commission

 100 F Street, N.E.

 Washington, D.C. 20549

 Attention: Christian Windsor

Re:
Partners Financial Corporation

 Registration
Statement on Form SB-2 (File No. 333-120068)

 Ladies and Gentlemen:

 Pursuant to Rule 461 of the General Rules and Regulations
under the Securities Act of 1933, as amended, Partners Financial Corporation hereby requests that the Commission accelerate the effective date of post-effective amendment number two to the above-referenced Registration Statement and declare such
post-effective amendment effective as of July 11, 2005 at 10:00 a.m., Washington, D.C. time, or as soon thereafter as possible. Partners Financial Corporation also requests the Commission to confirm such effective date and time in writing.

 Partners Financial Corporation hereby acknowledges that:

•

Should the Commission or the staff, acting pursuant to delegated authority, declare the filing effective, it does not foreclose the Commission from taking any action with respect to
the filing;

•

The action of the Commission or the staff, acting pursuant to delegated authority, in declaring the filing effective, does not relieve Partners Financial Corporation from its full
responsibility for the adequacy and accuracy of the disclosure in the filing; and

•

Partners Financial Corporation may not assert this action as defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United
States.

 Very truly yours,

 PARTNERS FINANCIAL CORPORATION

 /s/ Charles T. DeBilio

 Charles T. DeBilio

 Chief Financial Officer