SEC Comment Letter 0000000000-23-013492 to Eastern Bankshares, Inc. (EBC)
Eastern Bankshares, Inc.
Date: Dec. 12, 2023 · CIK: 0001810546 · Accession: 0000000000-23-013492
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United States securities and exchange commission logo December 11, 2023 James Fitzgerald Chief Financial Officer Eastern Bankshares, Inc. 265 Franklin Street Boston, MA 02110 Re:Eastern Bankshares, Inc. Form 10-K for the year ended December 31, 2022 Form 10-Q for the quarter ended September 30, 2023 Dear James Fitzgerald: We have reviewed your filings 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. Quarterly Report on Form 10-Q for the quarterly period ended September 30, 2023 Management of Market Risk, page 98 1.We note the reference on page 98 to "limits approved by the Risk Management Committee of [the] Board of Directors." Please revise future filings to include a materially complete description of how you seek to manage risks due to changes in interest rates and other material impacts on your operational facts and circumstances, including any management or corporate governance controls or procedures for identifying and responding to rapid changes in interest rates due to or as a result of exogenous or unknown factors. Please clarify the Risk Management Committee- or ALCO-approved limits and, with a view to disclosure, advise us of the extent to which the committees have approved risk profiles that do not conform to management and Board risk tolerances. Clarify the extent to which such limits and other policies and controls have been changed due to the economic and other developments referenced elsewhere. 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.
FirstName LastNameJames Fitzgerald Comapany NameEastern Bankshares, Inc. December 11, 2023 Page 2 FirstName LastName James Fitzgerald Eastern Bankshares, Inc. December 11, 2023 Page 2 Please contact Sarmad Makhdoom at 202-551-5776 or Michael Henderson at 202-551- 3364 if you have questions regarding comments on the financial statements and related matters. Please contact Madeleine Joy Mateo at 202-551-3465 or James Lopez at 202-551-3536 with any other questions. Sincerely, Division of Corporation Finance Office of Finance
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United States securities and exchange commission logo
December 11, 2023
James Fitzgerald
Chief Financial Officer
Eastern Bankshares, Inc.
265 Franklin Street
Boston, MA 02110
Re:Eastern Bankshares, Inc.
Form 10-K for the year ended December 31, 2022
Form 10-Q for the quarter ended September 30, 2023
Dear James Fitzgerald:
We have reviewed your filings 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.
Quarterly Report on Form 10-Q for the quarterly period ended September 30, 2023
Management of Market Risk, page 98
1.We note the reference on page 98 to "limits approved by the Risk Management
Committee of [the] Board of Directors." Please revise future filings to include a materially
complete description of how you seek to manage risks due to changes in interest rates and
other material impacts on your operational facts and circumstances, including any
management or corporate governance controls or procedures for identifying and
responding to rapid changes in interest rates due to or as a result of exogenous or
unknown factors. Please clarify the Risk Management Committee- or ALCO-approved
limits and, with a view to disclosure, advise us of the extent to which the committees
have approved risk profiles that do not conform to management and Board risk tolerances.
Clarify the extent to which such limits and other policies and controls have been changed
due to the economic and other developments referenced elsewhere.
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.
FirstName LastNameJames Fitzgerald
Comapany NameEastern Bankshares, Inc.
December 11, 2023 Page 2
FirstName LastName
James Fitzgerald
Eastern Bankshares, Inc.
December 11, 2023
Page 2
Please contact Sarmad Makhdoom at 202-551-5776 or Michael Henderson at 202-551-
3364 if you have questions regarding comments on the financial statements and related
matters. Please contact Madeleine Joy Mateo at 202-551-3465 or James Lopez at 202-551-3536
with any other questions.
Sincerely,
Division of Corporation Finance
Office of Finance