SEC Company Response from HOME BANCSHARES INC (HOMB) (CIK 0001331520) (HOMB) — Aug 26, 2014
HOME BANCSHARES INC (HOMB) (CIK 0001331520)
Date: Aug. 26, 2014 · CIK: 0001331520 · Accession: 0001193125-14-322016
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 000-51904
Letter
United States Securities and Exchange Commission Re: Home BancShares, Inc. Form 10-K for year ended December 31, 2013, filed February 28, 2014, incorporating from Schedule 14A filed on March 4, 2014 File No. 000-51904
Dear Mr. Samples:
As a follow up to our conversation this morning, you have requested that we provide additional information relating to disclosure made by Home BancShares, Inc. (the “Company”) in its Proxy Statement filed on March 4, 2014, which was incorporated into Item 13 of the Company’s Annual Report on Form 10-K filed on February 28, 2014. The relevant disclosure is included in the section titled “Certain Relationships and Related Transactions” under the subheading “Real Estate Transactions.”
We are providing this letter for the purpose of clarifying the disclosure made regarding lease payments to First Real Estate LTD Partnership LLLP, of which director Robert H. Adcock, Jr. is a partner, and to Conservative Development Company, a corporation controlled through common ownership by director Richard H. Ashley. During 2013, the aggregate payments made directly or indirectly to First Real Estate LTD Partnership LLP totaled $20,220 and the aggregate payments made directly or indirectly to Conservative Development Company totaled $77,720. First Real Estate LTD Partnership LLP and Conservative Development Company are not affiliated with each other and are not under common ownership. These transactions did not exceed $120,000 individually or in the aggregate.
Mr. Joshua Samples
August 26, 2014
Page
Please contact us immediately if you have any questions or if this is insufficient to complete our response to the Staff’s comment.
Sincerely,
MITCHELL, WILLIAMS, SELIG,
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CORRESP
1
filename1.htm
CORRESP
H. MAURICE MITCHELL
(1925-2011)
WILLIAM H.L. WOODYARD,
III
(1945-2014)
MICHELE
ALLGOOD
JOHN K. BAKER
SHERRY P. BARTLEY
STEVE BAUMAN
TRAV
BAXTER
R. T. BEARD, III
MICHELLE L. BROWNING
C.
DOUGLAS BUFORD, JR.
BURNIE
BURNER1
FREDERICK K.
CAMPBELL2
CHARLES B.
CLIETT, JR.3
KEN COOK
ELISABETH S. DELARGY5
JILL GRIMSLEY
DREWYOR6
DOAK
FOSTER2
BYRON
FREELAND
KAREN P. FREEMAN13
ALLAN GATES2
KATHLYN GRAVES
HAROLD W. HAMLIN
L.
KYLE HEFFLEY9
BEN D. JACKSON
ANTON L. JANIK, JR. 10
M. SAMUEL JONES III
TONY JUNEAU
JOHN
ALAN LEWIS
D. NICOLE LOVELL
WALTER E. MAY
BRUCE
MCCANDLESS III11
LANCE R. MILLER
STUART P. MILLER
T.
ARK MONROE, III2
MARSHALL S. NEY
JENNIFER R. PIERCE
CHRISTOPHER D. PLUMLEE
JULIE M. POMERANTZ16
LYN P. PRUITT
CHRISTOPHER T. ROGERS
J.
SCOTT SCHALLHORN
BARRY G. SKOLNICK12
DERRICK W. SMITH2
STAN D. SMITH
JEFFREY L. SPILLYARDS
CLAYBORNE S. STONE
JEFFREY THOMAS2
BRIAN A. VANDIVER
WALTER G. WRIGHT, JR.
TOD YESLOW7
425 WEST CAPITOL AVENUE,
SUITE 1800
LITTLE ROCK, ARKANSAS 72201-3525
TELEPHONE 501-688-8800
FAX 501-688-8807
9ANGELA ARTHERTON
MELISSA BANDY
1K.C. BARNER
CORY D. CHILDS
CRAIG R. COCKRELL
ALEX
T. GRAY
MEGAN HARGRAVES
CHRISTOPHER A. MCNULTY
KATIE M. PAPASAN
BRIAN
A. PIPKIN
KENDRA PRUITT
7KATHY SHARP
BRADFORD R. SHUMPERT
AMANDA L. STANTON
ZACHARY T. STEADMAN
MARY CATHERINE WAY
ADRIENNE L. WOODS
ASHLEY D. YOUNGER
COUNSEL
8BENJAMIN
D. BRENNER
JASON T. BROWNING
7ADRIA W. CONKLIN
COURTNEY C. CROUCH, III
JANE W. DUKE
15GEORGE R. ERNST
7MARTHA MCKENZIE HILL
4GINGER HYNEMAN
MARGARET A. JOHNSTON
1AMANDA L. MACLENNAN
KAREN
WHATLEY
OF COUNSEL
W. CHRISTOPHER BARRIER
JOSEPH W. GELZINE
DONALD H. HENRY
14HERMANN IVESTER
ANNE S. PARKER
1LARRY PARKS
JOHN S. SELIG
MARCELLA
J. TAYLOR
RICHARD A. WILLIAMS
2 ADMITTED IN DISTRICT OF COLUMBIA AND
ARKANSAS
3 ADMITTED IN ARIZONA, TEXAS AND
ARKANSAS
4 ADMITTED IN TENNESSEE AND ARKANSAS
5 ADMITTED IN TENNESSEE AND TEXAS
6 ADMITTED IN OKLAHOMA AND ARKANSAS
7 ADMITTED IN TEXAS AND ARKANSAS
8 ADMITTED IN CALIFORNIA AND ARKANSAS
9 ADMITTED IN MISSOURI AND ARKANSAS
WRITER’S DIRECT DIAL
501-688-8866
August 26, 2014
10 ADMITTED IN COLORADO AND
ARKANSAS
11 ADMITTED IN DISTRICT OF COLUMBIA,
NEW YORK, AND TEXAS
12 ADMITTED IN
NEW YORK AND PENNSYLVANIA
13 ADMITTED IN
DISTRICT OF COLUMBIA, TEXAS AND ARKANSAS
14
ADMITTED IN THE U.S. PATENT
AND TRADEMARK
OFFICE AND ARKANSAS
15 ADMITTED IN PENNSYLVANIA
AND ARKANSAS
16 ADMITTED IN GEORGIA AND
TEXAS
ALL OTHERS ADMITTED ONLY IN
ARKANSAS
Mr. Joshua Samples
United
States Securities and Exchange Commission
100 F Street N.E.
Washington, DC 20549
Re:
Home BancShares, Inc.
Form 10-K for year ended December 31, 2013, filed February 28, 2014,
incorporating from Schedule 14A filed on March 4, 2014
File No. 000-51904
Dear Mr. Samples:
As a follow up to our conversation this morning, you have requested that we provide additional information relating to disclosure made by Home
BancShares, Inc. (the “Company”) in its Proxy Statement filed on March 4, 2014, which was incorporated into Item 13 of the Company’s Annual Report on Form 10-K filed on February 28, 2014. The relevant disclosure is
included in the section titled “Certain Relationships and Related Transactions” under the subheading “Real Estate Transactions.”
We are providing this letter for the purpose of clarifying the disclosure made regarding lease payments to First Real Estate LTD Partnership
LLLP, of which director Robert H. Adcock, Jr. is a partner, and to Conservative Development Company, a corporation controlled through common ownership by director Richard H. Ashley. During 2013, the aggregate payments made directly or indirectly to
First Real Estate LTD Partnership LLP totaled $20,220 and the aggregate payments made directly or indirectly to Conservative Development Company totaled $77,720. First Real Estate LTD Partnership LLP and Conservative Development Company are not
affiliated with each other and are not under common ownership. These transactions did not exceed $120,000 individually or in the aggregate.
Mr. Joshua Samples
August 26, 2014
Page
2
Please contact us immediately if you have any questions or if this is insufficient to
complete our response to the Staff’s comment.
Sincerely,
MITCHELL, WILLIAMS, SELIG,
GATES & WOODYARD, P.L.L.C.
/s/ C. Douglas Buford, Jr.
CDB:lj
cc:
Mr. C. Randall Sims