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
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File numbers found in text: 333-235822
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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