SEC Comment Letter 0000000000-25-001001 to COASTAL FINANCIAL CORP (CCB) (CIK 0001437958) (CCB)
COASTAL FINANCIAL CORP (CCB) (CIK 0001437958)
Date: Jan. 30, 2025 · CIK: 0001437958 · Accession: 0000000000-25-001001
AI Filing Summary & Sentiment
File numbers found in text: 001-38589
Letter
January 30, 2025 Joel G. Edwards Executive Vice President and Chief Financial Officer Coastal Financial Corporation 5415 Evergreen Way Everett, WA 98203 Re:Coastal Financial Corporation Form 10-K for Fiscal Year Ended December 31, 2023 Response dated January 24, 2025 File No. 001-38589 Dear Joel G. Edwards: We have reviewed your January 24, 2025 response to our comment letter and have the following comments. 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 December 20, 2024 letter. Form 10-K for Fiscal Year Ended December 31, 2023 Concentrations of Credit Risk, page 7 We note your response to prior comment 4. We note that CCBX credit enhancement asset totaled $167 million at September 30, 2024 and BaaS credit enhancement income totaled $211 million for the nine months ended September 30, 2024 and appears to be material to your financial statements. Please revise future filings, in the Business section and/or other sections as appropriate, to provide a roll forward of the CCBX credit enhancement asset for each period presented, including increases related to expected losses recognized in the allowance for credit losses, reductions due to payments received, reductions due to credit loss recoveries, and any other adjustments with appropriate discussion or tell us why you do not believe this information is material. Additionally, please revise future filings to more clearly discuss when a payment is due from the CCBX partner (e.g., when the receivable is charged off) and 1.
January 30, 2025 Page 2 the contractual terms related to the timing of the payment from the CCBX partner (e.g., 30 days after charge-off, etc.). Noninterest Income, page 66 2.We note your response to prior comment 10. Please revise future filings to disclose and discuss any internal performance measures related to the BaaS program that you develop. Please contact Shannon Davis at 202-551-6687 or Michael Volley at 202-551-3437 if you have any questions. Sincerely, Division of Corporation Finance Office of Finance
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January 30, 2025
Joel G. Edwards
Executive Vice President and Chief Financial Officer
Coastal Financial Corporation
5415 Evergreen Way
Everett, WA 98203
Re:Coastal Financial Corporation
Form 10-K for Fiscal Year Ended December 31, 2023
Response dated January 24, 2025
File No. 001-38589
Dear Joel G. Edwards:
We have reviewed your January 24, 2025 response to our comment letter and have the
following comments.
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
December 20, 2024 letter.
Form 10-K for Fiscal Year Ended December 31, 2023
Concentrations of Credit Risk, page 7
We note your response to prior comment 4. We note that CCBX credit enhancement
asset totaled $167 million at September 30, 2024 and BaaS credit enhancement
income totaled $211 million for the nine months ended September 30, 2024 and
appears to be material to your financial statements. Please revise future filings, in the
Business section and/or other sections as appropriate, to provide a roll forward of the
CCBX credit enhancement asset for each period presented, including increases related
to expected losses recognized in the allowance for credit losses, reductions due to
payments received, reductions due to credit loss recoveries, and any other adjustments
with appropriate discussion or tell us why you do not believe this information is
material. Additionally, please revise future filings to more clearly discuss when a
payment is due from the CCBX partner (e.g., when the receivable is charged off) and 1.
January 30, 2025
Page 2
the contractual terms related to the timing of the payment from the CCBX partner
(e.g., 30 days after charge-off, etc.).
Noninterest Income, page 66
2.We note your response to prior comment 10. Please revise future filings to disclose
and discuss any internal performance measures related to the BaaS program that you
develop.
Please contact Shannon Davis at 202-551-6687 or Michael Volley at 202-551-3437 if
you have any questions.
Sincerely,
Division of Corporation Finance
Office of Finance