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SEC Company Response from Professional Holding Corp. (CIK 0001630856) — Jan 24, 2020

Professional Holding Corp. (CIK 0001630856)
Date: Jan. 24, 2020 · CIK: 0001630856 · Accession: 0001104659-20-006649

AI Filing Summary & Sentiment

File numbers found in text: 333-235822

Date
January 24, 2020
Author
/s/ Gustav L. Schmidt
Form
CORRESP
Company
Professional Holding Corp. (CIK 0001630856)

Letter

VIA EDGAR Division of Corporation Finance Attn: Julia Griffith Re: Professional Holding Corp. Registration Statement on Form S-1 File No. 333-235822

Dear Ms. Griffith:

On behalf of Professional Holding Corp. (the “Company”), we are furnishing supplemental information requested by the staff (the “Staff”) of the U.S. Securities & Exchange Commission (the “Commission”) during a telephone call on January 23, 2020 among the Staff and representatives of the Company, Gunster, Yoakley & Stewart, P.A., Covington & Burling LLP, and the underwriters [***].i

[***].ii

[***].iii

[***].iv

[***].v

[***].vi

Las Olas Centre, Suite 1400, 450 East Las Olas Boulevard · Fort Lauderdale, FL 33301-4206 | 954-462-2000 | Fax: 954-523-1722 | www.gunster.com

BOCA RATON · FORT LAUDERDALE · JACKSONVILLE · KEY LARGO · MIAMI · orlando · PALM BEACH · STUART · TALLAHASSEE · tampa · VERO BEACH · WEST PALM BEACh · Winter Park

CONFIDENTIAL TREATMENT REQUESTED BY PROFESSIONAL HOLDING CORP.

U.S. Securities and Exchange Commission

January 24, 2020

Page 2

Insofar as indemnification for liabilities arising under the Securities Act may be permitted for a Company director under the Company’s articles of incorporation, bylaws or the Florida Business Corporation Act, or pursuant to an indemnification agreement, the Company acknowledges that it is the opinion of the Commission that such indemnification is against public policy as expressed in the Securities Act and is therefore unenforceable.

Should you have any questions or want to discuss these matters further, please contact me at (954) 468-1373. When you have completed your review of this matter, please return this correspondence to me by mail to 450 E. Las Olas Blvd., Suite 1400, Fort Lauderdale, FL 33301. Additionally, we request that the Commission provide timely notice to the contact person identified on Page 1 of this correspondence before it permits any disclosure of the information contained herein.

Very truly yours,
/s/ Gustav L. Schmidt

Show Raw Text
CORRESP
1
filename1.htm

    Our File Number: 42282.00005

    Writer’s Direct Dial Number: (954) 468-1373

    Writer’s Direct Fax Number: (954) 888-2002

    Writer’s E-Mail Address: gschmidt@gunster.com

FOIA CONFIDENTIAL TREATMENT REQUEST

January 24, 2020

VIA EDGAR

CONFIDENTIAL TREATMENT REQUESTED BY
PROFESSIONAL HOLDING CORP. PURSUANT TO 17 CFR 200.83 – PLEASE CONTACT GUSTAV SCHMIDT TELEPHONE: (954) 468-1373 OR FAX: (954)
888-2002.

U.S. Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549-4561

Attn: Julia Griffith

    Re:
    Professional Holding Corp.

    Registration Statement on Form S-1

    File No. 333-235822

Dear Ms. Griffith:

On behalf of Professional
Holding Corp. (the “Company”), we are furnishing supplemental information requested by the staff (the “Staff”)
of the U.S. Securities & Exchange Commission (the “Commission”) during a telephone call on January
23, 2020 among the Staff and representatives of the Company, Gunster, Yoakley & Stewart, P.A., Covington & Burling LLP,
and the underwriters [***].i

[***].ii

[***].iii

[***].iv

[***].v

[***].vi

Las
Olas Centre, Suite 1400, 450 East Las Olas Boulevard · Fort
Lauderdale, FL 33301-4206 | 954-462-2000 | Fax: 954-523-1722 | www.gunster.com

BOCA
RATON · FORT
LAUDERDALE · JACKSONVILLE
· KEY
LARGO · MIAMI
· orlando
· PALM
BEACH · STUART
· TALLAHASSEE
· tampa
· VERO
BEACH · WEST
PALM BEACh · Winter
Park

CONFIDENTIAL TREATMENT REQUESTED BY PROFESSIONAL HOLDING CORP.

U.S. Securities and Exchange Commission

January 24, 2020

Page 2

Insofar as indemnification
for liabilities arising under the Securities Act may be permitted for a Company director under the Company’s articles of
incorporation, bylaws or the Florida Business Corporation Act, or pursuant to an indemnification agreement, the Company acknowledges
that it is the opinion of the Commission that such indemnification is against public policy as expressed in the Securities Act
and is therefore unenforceable.

Should you have any
questions or want to discuss these matters further, please contact me at (954) 468-1373. When you have completed your review of
this matter, please return this correspondence to me by mail to 450 E. Las Olas Blvd., Suite 1400, Fort Lauderdale, FL 33301. Additionally,
we request that the Commission provide timely notice to the contact person identified on Page 1 of this correspondence before it
permits any disclosure of the information contained herein.

    Very truly yours,

    /s/ Gustav L. Schmidt

    Gustav L. Schmidt

i
Rule 83 confidential treatment request made by Professional Holding Corp.; request Number 1

ii
Rule 83 confidential treatment request made by Professional Holding Corp.; request Number 2

iii
Rule 83 confidential treatment request made by Professional Holding Corp.; request Number 3

iv
Rule 83 confidential treatment request made by Professional Holding Corp.; request Number 4

v
Rule 83 confidential treatment request made by Professional Holding Corp.; request Number 5

vi
Rule 83 confidential treatment request made by Professional Holding Corp.; request Number 6