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SEC Comment Letter 0000000000-24-004986 to EWSB Bancorp, Inc. /MD/ (CIK 0002013792) (EWSB)

EWSB Bancorp, Inc. /MD/ (CIK 0002013792)
Date: May 2, 2024 · CIK: 0002013792 · Accession: 0000000000-24-004986

AI Filing Summary & Sentiment

File numbers found in text: 333-277828

Date
May 2, 2024
Author
Office of Finance
Form
UPLOAD
Company
EWSB Bancorp, Inc. /MD/ (CIK 0002013792)

Letter

United States securities and exchange commission logo May 2, 2024 Charles D. Schmalz Chief Executive Officer EWSB Bancorp, Inc. 109 West Second Street Kaukauna, WI 02492 Re:EWSB Bancorp, Inc. Amendment No. 1 to Registration Statement on Form S-1 Filed April 22, 2024 File No. 333-277828 Dear Charles D. Schmalz: We have reviewed your amended registration statement and have the following comments. Please respond to this letter by amending your registration statement and providing the requested information. If you do not believe a comment applies to your facts and circumstances or do not believe an amendment is appropriate, please tell us why in your response. After reviewing any amendment to your registration statement and the information you provide in response to this letter, we may have additional comments. Unless we note otherwise, any references to prior comments are to comments in our April 4, 2024 letter. Amendment No. 1 to Registration Statement on Form S-1 Provision for Credit Losses, page 58 1.We note your response to prior comment 12 and your revised disclosure on page 58. We also note from your disclosure on pages F-26 and F-27 that the increased provision during the twelve months ended December 31, 2023 was primarily attributable to large increases in the provision associated with one- to four-family real estate and consumer loans. Please revise to enhance your discussion to more comprehensively explain the reasons for changes in the amount of your provision for loan losses recorded during the period and the amount of the allowance for loan losses at period end when compared to observed changes in the credit quality of your loan portfolio. Please be as specific and detailed as needed to provide an investor with a clear understanding of any material observed changes in risk and how these changes, as well as any other key drivers, impacted each component of the allowance for loan losses established at period end with a focus on one- to four-

FirstName LastNameCharles D. Schmalz Comapany NameEWSB Bancorp, Inc. May 2, 2024 Page 2 FirstName LastName Charles D. Schmalz EWSB Bancorp, Inc. May 2, 2024 Page 2 family real estate loans and consumer loans. Please refer to Item 303(a) of Regulation S- K. Management of Market Risk, page 61 2.We note your response to prior comment 13 and reissue in part. Please disclose whether the changes referenced in the first paragraph below the two tables on page 63 were within the limits of your policies and guidelines for asset/liability management. Allocation of Allowance for Credit Losses, page 83 3.We note your response to prior comment 16 and your revised disclosure on page 83. Please enhance your discussion to reference or include the tabular presentation on page F- 26 depicting changes in the allowance for credit losses so an investor can more fully understand the impact of the transition adjustment of adopting ASC 326 on the comparative allocation of the allowance for loan loss table, including noted increases and decreases in the allocated amounts, such as those associated with one- to four-family real estate loans and consumer loans. Please contact Shannon Davis at 202-551-6687 or Ben Phippen at 202-551-3697 if you have questions regarding comments on the financial statements and related matters. Please contact Madeleine Joy Mateo at 202-551-3465 or Tonya Aldave at 202-551-3601 with any other questions. Sincerely, Division of Corporation Finance Office of Finance cc: Zachary A. Davis, Esq.

Show Raw Text
United States securities and exchange commission logo
May 2, 2024
Charles D. Schmalz
Chief Executive Officer
EWSB Bancorp, Inc.
109 West Second Street
Kaukauna, WI 02492
Re:EWSB Bancorp, Inc.
Amendment No. 1 to Registration Statement on Form S-1
Filed April 22, 2024
File No. 333-277828
Dear Charles D. Schmalz:
            We have reviewed your amended registration statement and have the following
comments.
            Please respond to this letter by amending your registration statement and providing the
requested information. If you do not believe a comment applies to your facts and circumstances
or do not believe an amendment is appropriate, please tell us why in your response.
            After reviewing any amendment to your registration statement and the information you
provide in response to this letter, we may have additional comments. Unless we note otherwise,
any references to prior comments are to comments in our April 4, 2024 letter.
Amendment No. 1 to Registration Statement on Form S-1
Provision for Credit Losses, page 58
1.We note your response to prior comment 12 and your revised disclosure on page 58. We
also note from your disclosure on pages F-26 and F-27 that the increased provision during
the twelve months ended December 31, 2023 was primarily attributable to large increases
in the provision associated with one- to four-family real estate and consumer loans. Please
revise to enhance your discussion to more comprehensively explain the reasons for
changes in the amount of your provision for loan losses recorded during the period and the
amount of the allowance for loan losses at period end when compared to observed
changes in the credit quality of your loan portfolio. Please be as specific and detailed as
needed to provide an investor with a clear understanding of any material observed changes
in risk and how these changes, as well as any other key drivers, impacted each component
of the allowance for loan losses established at period end with a focus on one- to four-

 FirstName LastNameCharles D. Schmalz
 Comapany NameEWSB Bancorp, Inc.
 May 2, 2024 Page 2
 FirstName LastName
Charles D. Schmalz
EWSB Bancorp, Inc.
May 2, 2024
Page 2
family real estate loans and consumer loans. Please refer to Item 303(a) of Regulation S-
K.
Management of Market Risk, page 61
2.We note your response to prior comment 13 and reissue in part. Please disclose whether
the changes referenced in the first paragraph below the two tables on page 63 were within
the limits of your policies and guidelines for asset/liability management.
Allocation of Allowance for Credit Losses, page 83
3.We note your response to prior comment 16 and your revised disclosure on page 83.
Please enhance your discussion to reference or include the tabular presentation on page F-
26 depicting changes in the allowance for credit losses so an investor can more fully
understand the impact of the transition adjustment of adopting ASC 326 on the
comparative allocation of the allowance for loan loss table, including noted increases and
decreases in the allocated amounts, such as those associated with one- to four-family real
estate loans and consumer loans.
            Please contact Shannon Davis at 202-551-6687 or Ben Phippen at 202-551-3697 if you
have questions regarding comments on the financial statements and related matters. Please
contact Madeleine Joy Mateo at 202-551-3465 or Tonya Aldave at 202-551-3601 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Finance
cc:       Zachary A. Davis, Esq.