Correspondence 0001552781-25-000029 from COASTAL FINANCIAL CORP (CCB) (CIK 0001437958) (CCB)
COASTAL FINANCIAL CORP (CCB) (CIK 0001437958)
Date: Feb. 13, 2025 · CIK: 0001437958 · Accession: 0001552781-25-000029
AI Filing Summary & Sentiment
File numbers found in text: 001-38589
Referenced dates: December 20, 2024, January 30, 2025
Letter
VIA EDGAR Division of Corporation Finance Attention: Shannon Davis and Michael Volley Re: Coastal Financial Corporation Form 10-K for Fiscal Year Ended December 31, 2023 Response dated January 24, 2025 File No. 001-38589
Dear Ms. Davis and Mr. Volley:
Set forth below is the response of Coastal Financial Corporation (the “Company” or “we”), to the comments received from the staff (the “Staff”) of the U.S. Securities and Exchange Commission by letter dated January 30, 2025, with respect to the Company’s Annual Report on Form 10-K for the fiscal year ended December 31, 2023, and the Company’s response, dated January 24, 2025, to the Staff’s prior letter dated December 20, 2024. For your convenience, we have reproduced the text of the Staff’s comments in bold text followed by the Company’s response.
Form 10-K for Fiscal Year Ended December 31, 2023
Concentrations of Credit Risk, page 7
1. Staff’s Comment:
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 the contractual terms related to the timing of the payment from the CCBX partner (e.g., 30 days after charge-off, etc.).
Response:
The Company respectfully acknowledges the Staff’s comment and will include the requested information in future filings.
Noninterest Income, page 66
2. Staff’s Comment:
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.
Response:
The Company respectfully acknowledges the Staff’s comment. As previously noted, no specific internal performance measures related to BaaS program income are currently used by management. We will include in future filings a discussion about any such internal performance measures that we develop going forward.
Please do not hesitate to call me at (425) 357-3687 if you have any questions or require any additional information.
Sincerely,
/s/ Joel Edwards
Show Raw Text
CORRESP
1
filename1.htm
COASTAL FINANCIAL CORPORATION
5415 Evergreen Way
Everett, WA 98203
February 13, 2025
VIA EDGAR
U. S. Securities and Exchange Commission
Division of Corporation Finance
100 F Street, N.E.
Washington D.C. 20549
Attention: Shannon Davis and Michael Volley
Re:
Coastal Financial Corporation
Form 10-K for Fiscal Year Ended December 31, 2023
Response dated January 24, 2025
File No. 001-38589
Dear Ms. Davis and Mr. Volley:
Set forth below is the response
of Coastal Financial Corporation (the “Company” or “we”), to the comments received from the staff
(the “Staff”) of the U.S. Securities and Exchange Commission by letter dated January 30, 2025, with respect to the
Company’s Annual Report on Form 10-K for the fiscal year ended December 31, 2023, and the Company’s response, dated January
24, 2025, to the Staff’s prior letter dated December 20, 2024. For your convenience, we have reproduced the text of the Staff’s
comments in bold text followed by the Company’s response.
Form 10-K for Fiscal Year Ended December 31, 2023
Concentrations of Credit Risk, page 7
1. Staff’s Comment:
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 the contractual terms related to the timing of the payment from the CCBX partner (e.g.,
30 days after charge-off, etc.).
Response:
The Company respectfully
acknowledges the Staff’s comment and will include the requested information in future filings.
Noninterest Income, page 66
2. Staff’s Comment:
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.
Response:
The Company respectfully
acknowledges the Staff’s comment. As previously noted, no specific internal performance measures related to BaaS program income
are currently used by management. We will include in future filings a discussion about any such internal performance measures that we
develop going forward.
Please do not hesitate to call
me at (425) 357-3687 if you have any questions or require any additional information.
Sincerely,
/s/ Joel Edwards
Joel Edwards
Executive Vice President and Chief Financial Officer
Cc:
Michael Reed, Covington & Burling LLP
(212) 841-1204
MReed@cov.com