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
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File numbers found in text: 001-35424
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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