SEC Comment Letter 0000000000-24-006799 to Skyline Bankshares, Inc. (SLBK) (CIK 0001657642) (SLBK)
Skyline Bankshares, Inc. (SLBK) (CIK 0001657642)
Date: June 13, 2024 · CIK: 0001657642 · Accession: 0000000000-24-006799
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File numbers found in text: 333-209052
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United States securities and exchange commission logo
June 13, 2024
Lori C. Vaught
Chief Financial Officer
Skyline Bankshares, Inc.
100 Jacksonville Circle
Floyd, Virginia 24091
Re:Skyline Bankshares, Inc.
Form 10-K for the Fiscal Year Ended December 31, 2023
File No. 333-209052
Dear Lori C. Vaught:
We have limited our review of your filing to the financial statements and related
disclosures and have the following comments.
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.
Form 10-K for the Fiscal Year Ended December 31,2023
Loans, page 36
1.We note your disclosure on page 77 that the owner occupied or non-owner occupied
commercial real estate (“CRE”) loans include loans are secured by office buildings and
complexes, warehouses, manufacturing facilities, retail facilities and other commercial
and industrial properties, among others. Please revise your disclosures, in future filings, to
quantify the amount of owner occupied and non-owner occupied CRE, as well as to
provide further disaggregation into the composition of your owner occupied and non-
owner occupied CRE loan portfolio by type (e.g., by office, warehouse, retail,
manufacturing, etc.) and other characteristics (e.g., current weighted average and/or range
of loan-to-value ratios, occupancy rates, etc.) material to an investor’s understanding of
your commercial real estate loan portfolio
2.In addition, please revise to describe the specific details of any risk management policies,
procedures or other actions undertaken by management, to the extent applicable, for your
commercial real estate lending in response to the current environment.
FirstName LastNameLori C. Vaught
Comapany NameSkyline Bankshares, Inc.
June 13, 2024 Page 2
FirstName LastName
Lori C. Vaught
Skyline Bankshares, Inc.
June 13, 2024
Page 2
Table 7. Maturity Schedule of Loans, as of December 31, 2023, page 37
3.We note your tabular disclosure of loan maturity information for your Real Estate loans as
of December 31, 2023. Please revise your disclosures, in future filings, to present loan
maturity information for each loan category (e.g., Construction & Development,
Farmland, Residential, Commercial Mortgage, etc.) for which disclosure is required in the
financial statements. Refer to Item 1404(a) of Regulation S-K.
In closing, we remind you that the company and its management are responsible for the
accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or
absence of action by the staff.
Please contact Sarmad Makhdoom at 202-551-5776 or Marc Thomas at 202-551-3452
with any questions.
Sincerely,
Division of Corporation Finance
Office of Finance