SEC Comment Letter 0000000000-24-013362 to Embassy Bancorp, Inc. (EMYB) (CIK 0001449794) (EMYB)
Embassy Bancorp, Inc. (EMYB) (CIK 0001449794)
Date: Dec. 4, 2024 · CIK: 0001449794 · Accession: 0000000000-24-013362
AI Filing Summary & Sentiment
File numbers found in text: 000-53528
Letter
December 4, 2024 Judith Hunsicker Chief Financial Officer Embassy Bancorp, Inc. One Hundred Gateway Drive Suite 100 Bethlehem, PA 18017 Re:Embassy Bancorp, Inc. Form 10-K for Fiscal Year Ended December 31, 2023 File No. 000-53528 Dear Judith Hunsicker: We have limited our review of your filing to the financial statements and related disclosures 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. Form 10-K for the fiscal year ended December 31, 2023 Capital Resources and Adequacy, page 46 1.We note that your presentation of tangible book value per share not including accumulated other comprehensive loss in the stockholders’ equity numerator (a non- GAAP measure) represents an individually tailored accounting measure given that the adjustment to exclude accumulated other comprehensive loss, net has the effect of changing the recognition and measurement principles required to be applied in accordance with GAAP. Therefore, please remove the presentation of this non-GAAP measure from future filings. Refer to Question 100.04 of the Division of Corporation Finance’s Compliance & Disclosure Interpretations on Non-GAAP Financial Measures and Rule 100(b) of Regulation G. In closing, we remind you that the company and its management are responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the staff.
December 4, 2024 Page 2 Please contact William Schroeder at 202-551-3294 or Ben Phippen at 202-551-3697 with any questions. Sincerely, Division of Corporation Finance Office of Finance
Show Raw Text
December 4, 2024
Judith Hunsicker
Chief Financial Officer
Embassy Bancorp, Inc.
One Hundred Gateway Drive
Suite 100
Bethlehem, PA 18017
Re:Embassy Bancorp, Inc.
Form 10-K for Fiscal Year Ended December 31, 2023
File No. 000-53528
Dear Judith Hunsicker:
We have limited our review of your filing to the financial statements and related
disclosures 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.
Form 10-K for the fiscal year ended December 31, 2023
Capital Resources and Adequacy, page 46
1.We note that your presentation of tangible book value per share not including
accumulated other comprehensive loss in the stockholders’ equity numerator (a non-
GAAP measure) represents an individually tailored accounting measure given that the
adjustment to exclude accumulated other comprehensive loss, net has the effect of
changing the recognition and measurement principles required to be applied in
accordance with GAAP. Therefore, please remove the presentation of this non-GAAP
measure from future filings. Refer to Question 100.04 of the Division of Corporation
Finance’s Compliance & Disclosure Interpretations on Non-GAAP Financial
Measures and Rule 100(b) of Regulation G.
In closing, we remind you that the company and its management are responsible for
the accuracy and adequacy of their disclosures, notwithstanding any review, comments,
action or absence of action by the staff.
December 4, 2024
Page 2
Please contact William Schroeder at 202-551-3294 or Ben Phippen at 202-551-3697
with any questions.
Sincerely,
Division of Corporation Finance
Office of Finance