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SEC Comment Letter for WATERSTONE FINANCIAL INC (CIK 0001329517) — Sep 14, 2005

WATERSTONE FINANCIAL INC (CIK 0001329517)
Date: Sept. 14, 2005 · CIK: 0001329517 · Accession: 0000000000-05-047490

AI Filing Summary & Sentiment

File numbers found in text: 333-125715

Date
July 29, 2005
Author
William C-L Friar
Form
UPLOAD
Company
WATERSTONE FINANCIAL INC (CIK 0001329517)

Letter

20549-0408 July 29, 2005 Donald J. Stephens President Wauwatosa Holdings, Inc. 11200 West Plank Court Wauwatosa, Wisconsin 523226

Re: Wauwatosa Holdings, Inc. Form S-1, amendment number 1 filed July 19, 2005 File Number 333-125715

Dear Mr. Stephens:

We have reviewed your amended Form S-1 and have the following comments. Where indicated, we think you should revise your documents in response to these comments. If you disagree, we will consider your explanation as to why our comment is inapplicable or a revision is unnecessary. Please be as detailed as necessary in your explanation. In some of our comments, we may ask you to provide us with supplemental information so we may better understand your disclosure. After reviewing this information we may have additional comments.

The purpose of our review process is to assist you in your compliance with the applicable disclosure requirements and to enhance the overall disclosure in your filing. We look forward to working with you in these respects. We welcome any questions you may have about our comments or on any other aspect of our review. Feel free to call us at the telephone numbers listed at the end of this letter.

How We Determined to Offer..., page 6

1. At the end of the first full paragraph on page 7 revise the text to explain that if subscribers do not affirm their purchase decision their funds will be returned.

Recent Results o Operations, page 15

2. In the first paragraph, please briefly disclose what the referenced dispute is about.

Sources of Funds - Deposits, page 70

3. Please revise the table that sets forth the maturity of outstanding certificates of deposit in amounts greater than or equal to $100,000 to reconcile with the balance of $274.6 million disclosed in the previous sentence.

* * * * *

Closing Comments

As appropriate, please amend your registration statement in response to these comments. You may wish to provide us with marked copies of the amendment to expedite our review. Please furnish a cover letter with your amendment that keys your responses to our comments and provides any requested supplemental information. Detailed cover letters greatly facilitate our review. Please understand that we may have additional comments after reviewing your amendment and responses to our comments.

Direct any questions on accounting matters to Matthew Komar at 202-551-3781, or to Don Walker, Senior Assistant Chief Accountant, at 202-551-3490. Please direct any other questions to David Lyon at 202-551-3421, or to me at 202-551-3418.

Sincerely,
William C-L Friar
Senior Financial Analyst

Show Raw Text
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<TEXT>

20549-0408

                           July 29, 2005

Donald J. Stephens
President
Wauwatosa Holdings, Inc.
11200 West Plank Court
Wauwatosa, Wisconsin  523226

Re: Wauwatosa Holdings, Inc.
       Form S-1, amendment number 1 filed July 19, 2005
       File Number 333-125715

Dear Mr. Stephens:

      We have reviewed your amended Form S-1 and have the
following
comments.  Where indicated, we think you should revise your
documents
in response to these comments.  If you disagree, we will consider
your explanation as to why our comment is inapplicable or a
revision
is unnecessary.  Please be as detailed as necessary in your
explanation.  In some of our comments, we may ask you to provide
us
with supplemental information so we may better understand your
disclosure.  After reviewing this information we may have
additional
comments.

      The purpose of our review process is to assist you in your
compliance with the applicable disclosure requirements and to
enhance
the overall disclosure in your filing.  We look forward to working
with you in these respects.  We welcome any questions you may have
about our comments or on any other aspect of our review.  Feel
free
to call us at the telephone numbers listed at the end of this
letter.

How We Determined to Offer..., page 6

1. At the end of the first full paragraph on page 7 revise the
text
to explain that if subscribers do not affirm their purchase
decision
their funds will be returned.

Recent Results o Operations, page 15

2. In the first paragraph, please briefly disclose what the
referenced dispute is about.

Sources of Funds - Deposits, page 70

3. Please revise the table that sets forth the maturity of
outstanding certificates of deposit in amounts greater than or
equal
to $100,000 to reconcile with the balance of $274.6 million
disclosed
in the previous sentence.

      *  *  *  *  *

Closing Comments

      As appropriate, please amend your registration statement in
response to these comments.  You may wish to provide us with
marked
copies of the amendment to expedite our review.  Please furnish a
cover letter with your amendment that keys your responses to our
comments and provides any requested supplemental information.
Detailed cover letters greatly facilitate our review.  Please
understand that we may have additional comments after reviewing
your
amendment and responses to our comments.

      Direct any questions on accounting matters to Matthew Komar
at
202-551-3781, or to Don Walker, Senior Assistant Chief Accountant,
at
202-551-3490.  Please direct any other questions to David Lyon at
202-551-3421, or to me at 202-551-3418.

      						Sincerely,

							William C-L Friar
      Senior Financial Analyst

By fax: Hoyt R. Stastney
	Fax number 414-978-8968

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Wauwatosa Holdings, Inc.
July 27, 2005
Page 2

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