SEC Comment Letter for HOME BANCSHARES INC (HOMB) (CIK 0001331520) (HOMB) — Mar 15, 2017
HOME BANCSHARES INC (HOMB) (CIK 0001331520)
Date: March 15, 2017 · CIK: 0001331520 · Accession: 0000000000-17-008637
AI Filing Summary & Sentiment
Reasoning
Letter
Mail Stop 4720 March 15, 2017 Brian Davis Chief Financial Officer Home Bancshares, Inc. 719 Harkrider, Suite 100 Conway, Arkansas 72032
Re: Home Bancshares, Inc. Form 10-K for Fiscal Year Ended December 31, 2016 Filed February 28, 2017 Form 8 -K Filed January 19, 2017 File No. 0 00-51904
Dear Mr. Davis :
We have limited our review of your filing to the financial statements and related disclosures and have the following comments. In some of our comments, we may ask you to provide us with information so we may better understand your disclosure.
Please respond to these comments within ten business days by providing the requested information or advise us as soon as possibl e when you will respond. If you do not believe our comments apply to your facts and circumstances, please tell us why in your response.
After reviewing your response to these comments, we may have additional comments.
Form 10 -K
Non-GAAP Financial M easurements, page 88
1. Please tell us how you considered whether the non -GAAP measure “Allowance for loan losses plus discount for credit losses on purchased loans to total loans plus discount for credit losses on purchased loans” uses an individually tailo red recognition and measurement method which could violate Rule 100(b) of Regulation G. Please refer to Question 100.04 of the Compliance and Disclosure Interpretations for guidance.
Brian Davis Home Bancshares, Inc. March 15, 2017 Page 2
Form 8 -K Filed January 19, 2017 – Exhibit 99.1
2. Please revise futur e Form 8 -K filings in which you present non -GAAP financial measures to disclose the information required in Rule 100(a) of Regulation G and Item 10(e)(1)(i) of Regulation S -K.
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.
You may contact Michael Volley, Staff Accountant, at 20 2-551-3437 or me at 202 -551- 3492 with any questions.
Sincerely,
/s/ John P. Nolan
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Mail Stop 4720 March 15, 2017 Brian Davis Chief Financial Officer Home Bancshares, Inc. 719 Harkrider, Suite 100 Conway, Arkansas 72032 Re: Home Bancshares, Inc. Form 10-K for Fiscal Year Ended December 31, 2016 Filed February 28, 2017 Form 8 -K Filed January 19, 2017 File No. 0 00-51904 Dear Mr. Davis : We have limited our review of your filing to the financial statements and related disclosures and have the following comments. In some of our comments, we may ask you to provide us with information so we may better understand your disclosure. Please respond to these comments within ten business days by providing the requested information or advise us as soon as possibl e when you will respond. If you do not believe our comments apply to your facts and circumstances, please tell us why in your response. After reviewing your response to these comments, we may have additional comments. Form 10 -K Non-GAAP Financial M easurements, page 88 1. Please tell us how you considered whether the non -GAAP measure “Allowance for loan losses plus discount for credit losses on purchased loans to total loans plus discount for credit losses on purchased loans” uses an individually tailo red recognition and measurement method which could violate Rule 100(b) of Regulation G. Please refer to Question 100.04 of the Compliance and Disclosure Interpretations for guidance. Brian Davis Home Bancshares, Inc. March 15, 2017 Page 2 Form 8 -K Filed January 19, 2017 – Exhibit 99.1 2. Please revise futur e Form 8 -K filings in which you present non -GAAP financial measures to disclose the information required in Rule 100(a) of Regulation G and Item 10(e)(1)(i) of Regulation S -K. 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. You may contact Michael Volley, Staff Accountant, at 20 2-551-3437 or me at 202 -551- 3492 with any questions. Sincerely, /s/ John P. Nolan John P. Nolan Senior Assistant Chief Accountant Office of Financial Services