SEC Comment Letter 0000000000-23-013337 to First Foundation Inc. (FFWM) (CIK 0001413837) (FFWM)
First Foundation Inc. (FFWM) (CIK 0001413837)
Date: Dec. 6, 2023 · CIK: 0001413837 · Accession: 0000000000-23-013337
AI Filing Summary & Sentiment
File numbers found in text: 001-36461
Letter
United States securities and exchange commission logo December 6, 2023 James Britton Executive Vice President and Chief Financial Officer First Foundation Inc. 200 Crescent Court, Suite 1400 Dallas, Texas 75201 Re:First Foundation Inc. Form 10-Q for Fiscal Quarter Ended June 30, 2023 Form 10-Q for Fiscal Quarter Ended September 30, 2023 Response dated November 6, 2023 File No. 001-36461 Dear James Britton: We have reviewed your November 6, 2023 response to our comment letter and have the following comment. Please respond to this letter within ten business days by providing the requested information or advise us as soon as possible when you will respond. If you do not believe a comment applies to your facts and circumstances, please tell us why in your response. After reviewing your response to this letter, we may have additional comments. Unless we note otherwise, any references to prior comments are to comments in our October 17, 2023 letter. Form 10-Q for Fiscal Quarter Ended September 30, 2023 General 1.We note your response to prior comment 5 regarding risk management, relevant limits and guidelines and risks due to changes in interest rates. It appears the disclosure you provided was focused on the 25% minimum liquidity ratio. However, the comment sought disclosure more generally of risk management policies and procedures. In this regard, we note your response to prior comment 7 and draft disclosure referencing the risk profile considering a number of factors and “clear policy limits and guidelines” that guide your IRR management strategies. Please revise future filings to provide a more fulsome description of the material aspects of risk management, including identification of other material limits and guidelines and your compliance with them. Please provide us with your proposed disclosures.
FirstName LastNameJames Britton Comapany NameFirst Foundation Inc. December 6, 2023 Page 2 FirstName LastName James Britton First Foundation Inc. December 6, 2023 Page 2 Please contact John Spitz at 202-551-3484 or Ben Phippen at 202-551-3697 if you have questions regarding comments on the financial statements and related matters. Please contact Todd Schiffman at 202-551-3491 or Susan Block at 202-551-3210 with any other questions. Sincerely, Division of Corporation Finance Office of Finance
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United States securities and exchange commission logo
December 6, 2023
James Britton
Executive Vice President and Chief Financial Officer
First Foundation Inc.
200 Crescent Court, Suite 1400
Dallas, Texas 75201
Re:First Foundation Inc.
Form 10-Q for Fiscal Quarter Ended June 30, 2023
Form 10-Q for Fiscal Quarter Ended September 30, 2023
Response dated November 6, 2023
File No. 001-36461
Dear James Britton:
We have reviewed your November 6, 2023 response to our comment letter and have the
following comment.
Please respond to this letter within ten business days by providing the requested
information or advise us as soon as possible when you will respond. If you do not believe a
comment applies to your facts and circumstances, please tell us why in your response.
After reviewing your response to this letter, we may have additional comments. Unless
we note otherwise, any references to prior comments are to comments in our October 17,
2023 letter.
Form 10-Q for Fiscal Quarter Ended September 30, 2023
General
1.We note your response to prior comment 5 regarding risk management, relevant limits and
guidelines and risks due to changes in interest rates. It appears the disclosure you provided
was focused on the 25% minimum liquidity ratio. However, the comment sought
disclosure more generally of risk management policies and procedures. In this regard, we
note your response to prior comment 7 and draft disclosure referencing the risk profile
considering a number of factors and “clear policy limits and guidelines” that guide your
IRR management strategies. Please revise future filings to provide a more fulsome
description of the material aspects of risk management, including identification of other
material limits and guidelines and your compliance with them. Please provide us with
your proposed disclosures.
FirstName LastNameJames Britton
Comapany NameFirst Foundation Inc.
December 6, 2023 Page 2
FirstName LastName
James Britton
First Foundation Inc.
December 6, 2023
Page 2
Please contact John Spitz at 202-551-3484 or Ben Phippen at 202-551-3697 if you have
questions regarding comments on the financial statements and related matters. Please contact
Todd Schiffman at 202-551-3491 or Susan Block at 202-551-3210 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Finance