SEC Comment Letter for HOME BANCORP, INC. (HBCP) (CIK 0001436425) (HBCP) — Sep 6, 2013
HOME BANCORP, INC. (HBCP) (CIK 0001436425)
Date: Sept. 6, 2013 · CIK: 0001436425 · Accession: 0000000000-13-049129
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September 6, 2013
Via E -mail
Joseph B. Zanco
Chief Financial Officer
Home Bancorp, Inc.
503 Kaliste Saloom Road
Lafayette, Louisiana 70508
Re: Home Bancorp, Inc.
Form 10-K for Fiscal Period Ended December 31, 2012
Form 10 -Q for the Quarterly Period Ended June 30, 2013
Filed March 15, 2013
File No. 001 -34190
Dear Mr. Zanco :
We have reviewed your filing an d 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 this letter within ten business days by amending your filing, by
providing the requested information, or by advising us when you will provide the requested
respo nse. If you do not believe our comments apply to your facts and circumstances or do not
believe an amendment is appropriate, please tell us why in your response.
After reviewing any amendment to your filing and the information you provide in
response t o these comments, we may have additional comments.
Form 10 -K for the fiscal year ended December 31, 2012
Consolidated Financial Statements
Notes to Consolidated Financial Statements
Note 5 – Loans, page 62
1. We note your disclosure on page 15 of the June 30, 2013 Form 10 -Q and page 66 of the
December 31, 2012 Form 10 -K that non -accrual non -covered loans were $16.9 million, $12.4
million and $11.0 million at June 30, 2013, December 31, 2012 and 2011, respectively.
Additionally, we also note th at these non -accrual loans include $11.3 million, $10.2 million
and $7.2 million of loans acquired from GSFC in July 2011, respectively. Given the
significance of these legacy GSFC loans to your total non -accrual loans, please tell us, and
revise future f ilings to address the following:
Joseph B. Zanco
Home Bancorp, Inc.
September 6, 2013
Page 2
The types of loans (one -to-four family, commercial real estate, etc) included in these non -
accrual loans acquired from GSFC;
Whether these non -accrual loans were accounted for under ASC 310 -30 (loans acquired
with deterio rated credit quality);
How you classified these acquired loans at acquisition (accrual, non -accrual, 90 days and
accruing, impaired and troubled debt restructurings). For example, discuss if these loans
are considered non -accrual and / or impaired immedi ately after acquisition and the
underlying reasons for your determination. Additionally, in all of your credit quality
disclosures (including disclosures of non -accrual referenced above), please clearly
disclose if purchased credit impaired loans are incl uded and quantify the amount.
When these loans became non -accrual along with the facts and circumstances related to
the credit quality of these newly acquired loans that resulted in this classification;
The allowance for loan losses associated with these loans, as applicable;
How any changes in credit quality related to these loans, as well as any other key drivers,
impacted each component of the allowance for loan losses; and
Any other pertinent information deemed necessary to understand your review of these
loans and related accounting for these loans as of the date of acquisition (July 2011)
through June 30, 2013.
We urge all persons who are responsible for the accuracy and adequacy of the disclosure
in the filing to be certain that the filing includes the information the Securities Exchange Act of
1934 and all applicable Exchange Act rules require. Since the company and its management are
in possession of all facts relating to a company’s disclosure, they are responsible for the accurac y
and adequacy of the disclosures they have made.
In responding to our comments, please provide a written statement from the company
acknowledging that:
the company is responsible for the adequacy and accuracy of the disclosure in the filin g;
staff comments or changes to disclosure in response to staff comments do not foreclose
the Commission from taking any action with respect to the filing; and
the company may not assert staff comments as a defense in any proceeding initiated by
the Comm ission or any person under the federal securities laws of the United States.
Joseph B. Zanco
Home Bancorp, Inc.
September 6, 2013
Page 3
You may contact Benjamin Phippen, Staff Accountant, at (202) 551 -3697 or me at (202)
551-3492 if you have questions regarding comments on the financial statements and related
matters.
Sincerely,
/s/ John P. Nolan
John P. Nolan
Senior Assistant Chief Accountant