SEC Comment Letter 0000000000-24-000224 to Eastern Bankshares, Inc. (EBC)
Eastern Bankshares, Inc.
Date: Jan. 5, 2024 · CIK: 0001810546 · Accession: 0000000000-24-000224
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 001-39610
Referenced dates: December 20, 2023
Letter
United States securities and exchange commission logo January 5, 2024 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 Response dated December 20, 2023 File No. 001-39610 Dear James Fitzgerald: We have reviewed your December 20, 2023 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 11, 2023 letter. Response Letter Dated December 20, 2023 General 1.We note your draft disclosure references management's belief that interest rate derivative financial instruments provide significant protection against falling interest rates. In light of increases in interest rates during the periods covered by your annual and quarterly reports, please revise your draft risk management discussion to further clarify whether and how derivatives are used to manage risk due to other interest rate environments, including any material adjustments to the strategy due to recent increases in interest rates. Additionally, please clarify whether the simulation and EVE model outputs reflect such use of derivatives. Please contact Sarmad Makhdoom at 202-551-5776 or Michael Henderson at 202-551-
FirstName LastNameJames Fitzgerald Comapany NameEastern Bankshares, Inc. January 5, 2024 Page 2 FirstName LastName James Fitzgerald Eastern Bankshares, Inc. January 5, 2024 Page 2 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 cc: Michael K. Krebs
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United States securities and exchange commission logo
January 5, 2024
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
Response dated December 20, 2023
File No. 001-39610
Dear James Fitzgerald:
We have reviewed your December 20, 2023 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 11,
2023 letter.
Response Letter Dated December 20, 2023
General
1.We note your draft disclosure references management's belief that interest rate derivative
financial instruments provide significant protection against falling interest rates. In light
of increases in interest rates during the periods covered by your annual and quarterly
reports, please revise your draft risk management discussion to further clarify whether and
how derivatives are used to manage risk due to other interest rate environments, including
any material adjustments to the strategy due to recent increases in interest rates.
Additionally, please clarify whether the simulation and EVE model outputs reflect such
use of derivatives.
Please contact Sarmad Makhdoom at 202-551-5776 or Michael Henderson at 202-551-
FirstName LastNameJames Fitzgerald
Comapany NameEastern Bankshares, Inc.
January 5, 2024 Page 2
FirstName LastName
James Fitzgerald
Eastern Bankshares, Inc.
January 5, 2024
Page 2
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
cc: Michael K. Krebs