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SEC Company Response from TEB Bancorp, Inc. (TBBA) (CIK 0001751700) — Feb 22, 2022

TEB Bancorp, Inc. (TBBA) (CIK 0001751700)
Date: Feb. 22, 2022 · CIK: 0001751700 · Accession: 0000943374-22-000100

AI Filing Summary & Sentiment

File numbers found in text: 000-56049

Referenced dates: February 14, 2022

Date
February 22, 2022
Author
/s/ Ned Quint
Form
CORRESP
Company
TEB Bancorp, Inc. (TBBA) (CIK 0001751700)

Letter

LUSE GORMAN, PC

ATTORNEYS AT LAW

5335 Wisconsin Avenue, NW, Suite 780

Washington, D.C. 20015

—————

Telephone (202) 274-2000

Facsimile (202) 362-2902

www.luselaw.com

WRITER’S DIRECT DIAL NUMBER

(202) 274-2007

WRITER’S EMAIL

nquint@luselaw.com

February 22, 2022

VIA EDGAR

Securities and Exchange Commission

Division of Corporation Finance

Office of Financial Services

100 F Street, N.E.

Washington, D.C. 20549-4720

Re:

TEB Bancorp, Inc.

Form 10-K for Fiscal Year Ended June 30, 2021

Filed on September 23, 2021

File No. 000-56049

Ladies and Gentlemen:

On behalf of TEB Bancorp, Inc. (the “Company”), set forth below is the comment from the Staff’s comment letter dated February 14, 2022, regarding the above-referenced Annual Report on Form 10-K, as well as the Company’s response to the comment.

Form 10-K Filed on September 23, 2021

ITEM 9A. Controls and Procedures, page 51

1.

Please amend your filing to provide all of the disclosures required by Item 308(a) of Regulation S-K regarding management’s assessment of internal control over financial reporting. Please ensure that you address the following:

•

Identify the framework used by management to evaluate internal control over financial reporting, whether the criteria set forth by COSO or another framework. Refer to Item 308(a)(2).

•

Include a definitive statement as to whether or not your internal control over financial reporting is effective at the end of your most recent fiscal year. Refer to Item 308(a)(3).

The Company has filed Amendment No. 1 to its Annual Report on Form 10-K to revise Item 9A to include the following:

The Company’s management assessed the effectiveness of the Company’s internal control over financial reporting as of June 30, 2021. In making this assessment, we used the criteria set forth by the Committee of Sponsoring Organizations of the Treadway Commission in Internal Control-Integrated Framework (2013). Based on our assessment we concluded that, as of June 30, 2021, the Company’s internal control over financial reporting was effective based on those criteria.

This annual report does not include an attestation report of the Company’s registered public accounting firm regarding internal control over financial reporting. As the Company is a non-accelerated filer, management’s report is not subject to attestation by the Company’s registered public accounting firm pursuant to provisions of the Dodd-Frank Act that permit the Company to provide only the management’s report in this annual report.

* * * * *

We trust the foregoing is responsive to the Staff’s comment. Please advise the undersigned at (202) 274-2007 if there are any further comments or questions.

Respectfully,
/s/ Ned Quint

Show Raw Text
CORRESP
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filename1.htm

    LUSE GORMAN, PC

    ATTORNEYS AT LAW

    5335 Wisconsin Avenue, NW, Suite 780

    Washington, D.C.  20015

    —————

    Telephone (202) 274-2000

    Facsimile (202) 362-2902

    www.luselaw.com

            WRITER’S DIRECT DIAL NUMBER

            (202) 274-2007

            WRITER’S EMAIL

            nquint@luselaw.com

    February 22, 2022

    VIA EDGAR

    Securities and Exchange Commission

    Division of Corporation Finance

    Office of Financial Services

    100 F Street, N.E.

    Washington, D.C.  20549-4720

          Re:

            TEB Bancorp, Inc.

    Form 10-K for Fiscal Year Ended June 30, 2021

    Filed on September 23, 2021

    File No. 000-56049

    Ladies and Gentlemen:

    On behalf of TEB Bancorp, Inc. (the “Company”), set forth below is the comment from the Staff’s comment letter dated February 14, 2022,
      regarding the above-referenced Annual Report on Form 10-K, as well as the Company’s response to the comment.

    Form 10-K Filed on September 23, 2021

    ITEM 9A. Controls and Procedures, page 51

          1.

            Please amend your filing to provide all of the disclosures required by Item 308(a) of Regulation S-K regarding management’s assessment of internal
              control over financial reporting. Please ensure that you address the following:

          •

            Identify the framework used by management to evaluate internal control over financial reporting, whether the criteria set forth by COSO or another
              framework. Refer to Item 308(a)(2).

          •

            Include a definitive statement as to whether or not your internal control over financial reporting is effective at the end of your most recent fiscal
              year. Refer to Item 308(a)(3).

    The Company has filed Amendment No. 1 to its Annual Report on Form 10-K to revise Item 9A to include the following:

    The Company’s management assessed the effectiveness of the Company’s internal control over financial
      reporting as of June 30, 2021. In making this assessment, we used the criteria set forth by the Committee of Sponsoring Organizations of the Treadway Commission in Internal Control-Integrated Framework (2013).  Based on our assessment we concluded
      that, as of June 30, 2021, the Company’s internal control over financial reporting was effective based on those criteria.

    This annual report does not include an attestation report of the Company’s registered public
      accounting firm regarding internal control over financial reporting. As the Company is a non-accelerated filer, management’s report is not subject to attestation by the Company’s registered public accounting firm pursuant to provisions of the
      Dodd-Frank Act that permit the Company to provide only the management’s report in this annual report.

    *   *   *   *   *

    We trust the foregoing is responsive to the Staff’s comment.  Please advise the undersigned at (202) 274-2007 if there are any further
      comments or questions.

    Respectfully,

    /s/ Ned Quint

    Ned Quint

               cc:

              Jennifer L. Provancher, President and

                 Chief Executive Officer

              Kip Weissman, Esq.