SEC Comment Letter for Esquire Financial Holdings, Inc. (ESQ) (CIK 0001531031) (ESQ) — May 4, 2017
Esquire Financial Holdings, Inc. (ESQ) (CIK 0001531031)
Date: May 4, 2017 · CIK: 0001531031 · Accession: 0000000000-17-015771
AI Filing Summary & Sentiment
Reasoning
Letter
Mail Stop 4720 May 4, 2017 Andrew C. Sagliocca President and Chief Executive Officer Esquire Financial Holdings, Inc. 320 Old Country Road, Suite 101 Garden City, NY 11530
Re: Esquire Financial Holdings, Inc. Amendment No. 1 to Draft Registration Statement on Form S -1 Submitted April 12, 2017 CIK No . 0001531031
Dear Ms. Sagliocca :
We have reviewed your amended draft registration statement and 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 by providing the requested information and either submitting an amended draft registration statement or publicl y filing your registration statement on EDGAR. If you do not believe our comments apply to your facts and circumstances or do not believe an amendment is appropriate, please tell us why in your response.
After reviewing the information you provide in r esponse to these comments and your amended draft registration statement or filed registration statement, we may have additional comments.
Prospectus Summary
Our Competitive Strengths, page 3
1. We note your response to comment 4. Please further balance your disclosure regarding your business and growth strategies as well as competitive strengths by providing a brief summary of the most significant risks that your business faces in the Summary se ction.
Business
Lending Activities, page 69
2. Clarify the percentage of total loans represented by each of attorney consumer loans and real estate loans.
Andrew C. Sagliocca Esquire Financial Holdings, Inc. May 4, 2017 Page 2
You may contact William Schroeder at 202-551-3294 or Amit Pande at 202-551-3423 if you have questions regarding comments on the financial statements and related matters. Please contact Jessica Livingston at 202-551-3448 or me at 202-551-3391 with any other questions.
Sincerely,
/s/ Erin E. Martin
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Mail Stop 4720
May 4, 2017
Andrew C. Sagliocca
President and Chief Executive Officer
Esquire Financial Holdings, Inc.
320 Old Country Road, Suite 101
Garden City, NY 11530
Re: Esquire Financial Holdings, Inc.
Amendment No. 1 to Draft Registration Statement on Form S -1
Submitted April 12, 2017
CIK No . 0001531031
Dear Ms. Sagliocca :
We have reviewed your amended draft registration statement and 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 by providing the requested information and either submitting
an amended draft registration statement or publicl y filing your registration statement on
EDGAR. If you do not believe our comments apply to your facts and circumstances or do not
believe an amendment is appropriate, please tell us why in your response.
After reviewing the information you provide in r esponse to these comments and your
amended draft registration statement or filed registration statement, we may have additional
comments.
Prospectus Summary
Our Competitive Strengths, page 3
1. We note your response to comment 4. Please further balance your disclosure regarding
your business and growth strategies as well as competitive strengths by providing a brief
summary of the most significant risks that your business faces in the Summary se ction.
Business
Lending Activities, page 69
2. Clarify the percentage of total loans represented by each of attorney consumer loans and
real estate loans.
Andrew C. Sagliocca
Esquire Financial Holdings, Inc.
May 4, 2017
Page 2
You may contact William Schroeder at 202-551-3294 or Amit Pande at 202-551-3423
if you have questions regarding comments on the financial statements and related matters.
Please contact Jessica Livingston at 202-551-3448 or me at 202-551-3391 with any other
questions.
Sincerely,
/s/ Erin E. Martin
Erin E. Martin
Special Counsel
Office of Financial Services
cc: John J. Gorman, Esq.