Correspondence 0001193125-24-193687 from FB Bancorp, Inc. /MD/ (FBLA) (CIK 0002013639) (FBLA)
FB Bancorp, Inc. /MD/ (FBLA) (CIK 0002013639)
Date: Aug. 5, 2024 · CIK: 0002013639 · Accession: 0001193125-24-193687
AI Filing Summary & Sentiment
File numbers found in text: 333-277630
Letter
VIA EDGAR Securities and Exchange Commission Division of Corporation Finance Office of Finance Re: Re: FB Bancorp, Inc. Amendment No. 5 to Registration Statement on Form S-1 Filed July 18, 2024 File No. 333-277630
Dear Mr. Arzonetti:
FB Bancorp, Inc. (the “Company”) is in receipt of the correspondence from the Securities and Exchange Commission (the “SEC”) dated July 26, 2024 related to the SEC’s review of the Company’s Amendment No. 5 to the Registration Statement on Form S-1 (the “Registration Statement”). Our response to the comment is set forth below. For the convenience of the SEC Staff, we have repeated the comment in bold, followed by our response.
Amendment No. 5 to Form S-1
Risk factors, page 12
1. We note your disclosure in the third from last paragraph on page 35 that your that your average balance of loans held for investment during the six months ended June 30, 2024 increased by $114.3 million, or 19.6%, compared to June 30, 2023. We also note that the average balance of loans increased approximately 28.9% since December 31, 2022. In light of this, please include a new risk factor discussing the rapid increases in the loan portfolio and the fact that many of these loans are not seasoned enough to demonstrate any problems.
The Prospectus has been revised to include a new risk factor in response to the Staff’s comment. Please see “Risk Factors – The unseasoned nature of recently originated loans, in particular, commercial real estate and commercial loans, may result in changes in estimating collectability, which may lead to additional provisions or charge-offs, which could hurt our profits.”
Securities and Exchange Commission
Division of Corporate Finance
Office of Finance
August 5, 2024
Page 2 of 2
* * *
The Company believes the foregoing provides a complete response to the Comment Letter. If you have questions regarding the foregoing or require any additional information, please feel free to contact me at mlevy@luselaw.com or (202) 274-2009.
Very truly yours,
/s/ Marc Levy
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CORRESP 1 filename1.htm CORRESP LUSE GORMAN, PC ATTORNEYS AT LAW 5335 WISCONSIN AVENUE, N.W., SUITE 780 WASHINGTON, D.C. 20015 TELEPHONE (202) 274-2000 FACSIMILE (202) 362-2902 www.luselaw.com WRITER’S DIRECT DIAL NUMBER WRITER’S EMAIL (202) 274-2009 mlevy@luselaw.com August 5, 2024 VIA EDGAR Robert Arzonetti Securities and Exchange Commission Division of Corporation Finance Office of Finance Washington, D.C. 20549-3561 Re: Re: FB Bancorp, Inc. Amendment No. 5 to Registration Statement on Form S-1 Filed July 18, 2024 File No. 333-277630 Dear Mr. Arzonetti: FB Bancorp, Inc. (the “Company”) is in receipt of the correspondence from the Securities and Exchange Commission (the “SEC”) dated July 26, 2024 related to the SEC’s review of the Company’s Amendment No. 5 to the Registration Statement on Form S-1 (the “Registration Statement”). Our response to the comment is set forth below. For the convenience of the SEC Staff, we have repeated the comment in bold, followed by our response. Amendment No. 5 to Form S-1 Risk factors, page 12 1. We note your disclosure in the third from last paragraph on page 35 that your that your average balance of loans held for investment during the six months ended June 30, 2024 increased by $114.3 million, or 19.6%, compared to June 30, 2023. We also note that the average balance of loans increased approximately 28.9% since December 31, 2022. In light of this, please include a new risk factor discussing the rapid increases in the loan portfolio and the fact that many of these loans are not seasoned enough to demonstrate any problems. The Prospectus has been revised to include a new risk factor in response to the Staff’s comment. Please see “Risk Factors – The unseasoned nature of recently originated loans, in particular, commercial real estate and commercial loans, may result in changes in estimating collectability, which may lead to additional provisions or charge-offs, which could hurt our profits.” Securities and Exchange Commission Division of Corporate Finance Office of Finance August 5, 2024 Page 2 of 2 * * * The Company believes the foregoing provides a complete response to the Comment Letter. If you have questions regarding the foregoing or require any additional information, please feel free to contact me at mlevy@luselaw.com or (202) 274-2009. Very truly yours, /s/ Marc Levy Marc Levy cc: Christopher Ferris, FB Bancorp, Inc. John Spitz Katherine Garrett Todd Schiffman Thomas P. Hutton Lawrence M.F. Spaccasi