SEC Comment Letter 0000000000-25-003772 to National Bank Holdings Corp (NBHC)
National Bank Holdings Corp
Date: April 9, 2025 · CIK: 0001475841 · Accession: 0000000000-25-003772
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 001-35654
Letter
Re: National Bank Holdings Corporation Form 10-K for Fiscal Year Ended December 31, 2024 File No. 001-35654 Dear Nicole Van Denabeele:
April 9, 2025
Nicole Van Denabeele Chief Financial Officer National Bank Holdings Corporation 7800 East Orchard Road, Suite 300 Greenwood Village, CO 80111
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 Fiscal Year Ended December 31, 2024 Tangible Common Book Value Ratios, page 47
1. We note your presentation, here and in Exhibit 99.1 of your earnings release 8-K dated January 22, 2025, of non-GAAP measures tangible common book value, excluding accumulated other comprehensive loss, net of tax and tangible common book value per share, excluding accumulated other comprehensive loss, net of tax. These measures exclude the impact of accumulated other comprehensive income / loss ( AOCI/L ) and represent individually tailored accounting measures, given that the adjustments to exclude AOCI have the effect of changing the recognition and measurement principles required to be applied in accordance with GAAP. Please remove the presentation of these non-GAAP measures from your 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, April 9, 2025 Page 2
action or absence of action by the staff.
Please contact Mengyao Lu at 202-551-3471 or Cara Lubit at 202-551-5909 with any questions.
Sincerely,
Division of Corporation
Finance
Office of Finance
Show Raw Text
<DOCUMENT> <TYPE>TEXT-EXTRACT <SEQUENCE>2 <FILENAME>filename2.txt <TEXT> April 9, 2025 Nicole Van Denabeele Chief Financial Officer National Bank Holdings Corporation 7800 East Orchard Road, Suite 300 Greenwood Village, CO 80111 Re: National Bank Holdings Corporation Form 10-K for Fiscal Year Ended December 31, 2024 File No. 001-35654 Dear Nicole Van Denabeele: 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 Fiscal Year Ended December 31, 2024 Tangible Common Book Value Ratios, page 47 1. We note your presentation, here and in Exhibit 99.1 of your earnings release 8-K dated January 22, 2025, of non-GAAP measures tangible common book value, excluding accumulated other comprehensive loss, net of tax and tangible common book value per share, excluding accumulated other comprehensive loss, net of tax. These measures exclude the impact of accumulated other comprehensive income / loss ( AOCI/L ) and represent individually tailored accounting measures, given that the adjustments to exclude AOCI have the effect of changing the recognition and measurement principles required to be applied in accordance with GAAP. Please remove the presentation of these non-GAAP measures from your 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, April 9, 2025 Page 2 action or absence of action by the staff. Please contact Mengyao Lu at 202-551-3471 or Cara Lubit at 202-551-5909 with any questions. Sincerely, Division of Corporation Finance Office of Finance </TEXT> </DOCUMENT>