SEC Comment Letter 0000000000-24-000241 to FB Financial Corp (FBK)
FB Financial Corp
Date: Jan. 8, 2024 · CIK: 0001649749 · Accession: 0000000000-24-000241
AI Filing Summary & Sentiment
File numbers found in text: 001-37875
Letter
United States securities and exchange commission logo January 8, 2024 Michael M. Mettee Chief Financial Officer FB Financial Corporation 1221 Broadway, Suite 1300 Nashville, TN 37203 Re:FB Financial Corporation Form 8-K Filed October 16, 2023 Response dated January 2, 2024 File No. 001-37875 Dear Michael M. Mettee: We have reviewed your January 2, 2024 response to our comment letter and have the following comment. Please respond to this letter within ten business days by providing the requested information or advise us as soon as possible when you will respond. If you do not believe a comment applies to your facts and circumstances, please tell us why in your response. After reviewing your response to this letter, we may have additional comments. Unless we note otherwise, any references to prior comments are to comments in our December 15, 2023 letter. Form 8-K Filed October 16, 2023 Exhibit 99.2 Non-GAAP Reconciliations, page 17 1.We note your response to prior comment 2. Your presentations of adjusted tangible common equity and adjusted tangible book value per share, both of which exclude the impact of accumulated other comprehensive loss, net, represent individually tailored accounting measures given that the adjustment to exclude accumulated other comprehensive loss, net has the effect of changing the recognition and measurement principles required to be applied in accordance with GAAP. Therefore, please remove the presentation of these non-GAAP measures from your future filings. Refer to Question 100.04 of the Division of Corporation Finance’s Compliance & Disclosure Interpretations on Non-GAAP Financial Measures and Rule 100(b) of Regulation G.
FirstName LastNameMichael M. Mettee Comapany NameFB Financial Corporation January 8, 2024 Page 2 FirstName LastName Michael M. Mettee FB Financial Corporation January 8, 2024 Page 2 Please contact Katharine Garrett at 202-551-2332 or John Spitz at 202-551-3484 if you have questions regarding comments on the financial statements and related matters. Sincerely, Division of Corporation Finance Office of Finance
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United States securities and exchange commission logo
January 8, 2024
Michael M. Mettee
Chief Financial Officer
FB Financial Corporation
1221 Broadway, Suite 1300
Nashville, TN 37203
Re:FB Financial Corporation
Form 8-K Filed October 16, 2023
Response dated January 2, 2024
File No. 001-37875
Dear Michael M. Mettee:
We have reviewed your January 2, 2024 response to our comment letter and have the
following comment.
Please respond to this letter within ten business days by providing the requested
information or advise us as soon as possible when you will respond. If you do not believe a
comment applies to your facts and circumstances, please tell us why in your response.
After reviewing your response to this letter, we may have additional comments. Unless
we note otherwise, any references to prior comments are to comments in our December 15,
2023 letter.
Form 8-K Filed October 16, 2023
Exhibit 99.2
Non-GAAP Reconciliations, page 17
1.We note your response to prior comment 2. Your presentations of adjusted tangible
common equity and adjusted tangible book value per share, both of which exclude the
impact of accumulated other comprehensive loss, net, represent individually tailored
accounting measures given that the adjustment to exclude accumulated other
comprehensive loss, net has the effect of changing the recognition and measurement
principles required to be applied in accordance with GAAP. Therefore, please remove the
presentation of these non-GAAP measures from your future filings. Refer to Question
100.04 of the Division of Corporation Finance’s Compliance & Disclosure Interpretations
on Non-GAAP Financial Measures and Rule 100(b) of Regulation G.
FirstName LastNameMichael M. Mettee
Comapany NameFB Financial Corporation
January 8, 2024 Page 2
FirstName LastName
Michael M. Mettee
FB Financial Corporation
January 8, 2024
Page 2
Please contact Katharine Garrett at 202-551-2332 or John Spitz at 202-551-3484 if you
have questions regarding comments on the financial statements and related matters.
Sincerely,
Division of Corporation Finance
Office of Finance