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SEC Comment Letter for HomeStreet, Inc. (HMST) (CIK 0001518715) (MCHB) — Sep 16, 2014

HomeStreet, Inc. (HMST) (CIK 0001518715)
Date: Sept. 16, 2014 · CIK: 0001518715 · Accession: 0000000000-14-046460

AI Filing Summary & Sentiment

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Summary

Reasoning

File numbers found in text: 001-35424

Date
December 31, 2013
Author
/s/ Gus Rodriguez
Form
UPLOAD
Company
HomeStreet, Inc. (HMST) (CIK 0001518715)

Letter

September 16 , 2014 Via E -mail Cory D. Stewart Execut ive Vice President and Chief Accounting Officer HomeStreet, Inc. 601 Union Street, Suite 2000 Seattle, Washington 98101

Re: HomeStreet, Inc. Form 10 -K for the Fiscal Year Ended December 31, 2013 Filed March 17, 2014 File No. 001-35424

Dear Mr. Stewart :

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 response. If you do not believe our comments apply t o 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 to these comments, we may have additional comment s.

Genera l

1. Please provide us and revise future filings to include a complete description of your loan underwriting policies and procedures for each loan category and for each major loan type within each category, as appropriate. Also, please expand the footnotes to the financial statements to discuss the risks characteristics surrounding your receivables. Refer to ASC 310 -10-50-11B (a) 2 .

Cory D. Stewart HomeStreet, Inc. September 16 , 2014 Page 2

Item 8. Financial Statements and Supplementary Data

Financial Statements

Note 21- Parent Company Financial Statements

Consoli dated Statements of Cash Flows, page 174

2. You classify dividends received from your banking subsidiary of $19,600 in 2013 as cash flows from financing activities. Please tell us why you classified these cash inflows to the parent company as financing cash flows as opposed to operating cash flows. Please refer to ASC 230-10-45-16(b) for specific guidance on how to classify dividends received on a statement of cash flows.

We urge all persons who are responsible for the accuracy and adequacy of the disclos ure 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 disclos ure, they are responsible for the accuracy 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 filing;

 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 pr oceeding initiated by the Commission or any person under the federal securities laws of the United States.

You may contact Chris Harley at (202) 551 -3695 or me at (202) 551 -3752 if you have questions regarding comments on the financial statements and related matte rs.

Sincerely,
/s/ Gus Rodriguez

Show Raw Text
September 16 , 2014

Via E -mail
Cory D. Stewart
Execut ive Vice President and
Chief Accounting Officer
HomeStreet, Inc.
601 Union Street, Suite 2000
Seattle, Washington 98101

Re: HomeStreet, Inc.
Form 10 -K for the Fiscal Year Ended December 31, 2013
Filed March 17, 2014
File No. 001-35424

Dear Mr. Stewart :

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
response.   If you do not believe our comments apply t o 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 to these  comments, we may have  additional comment s.

Genera l

1. Please provide us and revise future filings to include a complete description of your
loan underwriting policies and procedures for each loan category and for each major
loan type within each category, as appropriate.  Also, please expand  the footnotes to
the financial statements to discuss the risks characteristics  surrounding your
receivables.  Refer to ASC 310 -10-50-11B (a) 2 .

Cory D. Stewart
HomeStreet, Inc.
September 16 , 2014
Page 2

Item 8. Financial Statements and Supplementary Data

Financial Statements

Note 21- Parent Company  Financial Statements

Consoli dated Statements of Cash Flows, page 174

2. You classify dividends received from your banking subsidiary of $19,600 in 2013 as
cash flows from financing activities.  Please tell us why you classified these cash
inflows to the parent company as financing cash  flows as opposed to operating cash
flows.  Please refer to ASC  230-10-45-16(b) for specific guidance on how to classify
dividends received on a statement of cash flows.

We urge all persons who are responsible for the accuracy and adequacy of the disclos ure
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 disclos ure, they are responsible for the accuracy
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 filing;

 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 pr oceeding initiated by
the Commission or any person under the federal securities laws of the United States.

You may contact Chris Harley  at (202) 551 -3695  or me at (202) 551 -3752  if you have
questions regarding comments on the financial statements and related matte rs.

Sincerely,

 /s/ Gus Rodriguez

            Gus Rodriguez
Accounting Branch Chief