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Esquire Financial Holdings, Inc.
Response Received
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Esquire Financial Holdings, Inc.
Response Received
1 company response(s)
High - file number match
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Esquire Financial Holdings, Inc.
Response Received
1 company response(s)
High - file number match
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Esquire Financial Holdings, Inc.
Response Received
1 company response(s)
High - file number match
SEC wrote to company
2018-10-11
Esquire Financial Holdings, Inc.
Filing - SEC Comment Letter to Esquire Financial Holdings, Inc.
UPLOAD · 2018-10-11
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Company responded
2018-10-11
Esquire Financial Holdings, Inc.
Filing - Correspondence from Esquire Financial Holdings, Inc.
CORRESP · 2018-10-11
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Esquire Financial Holdings, Inc.
Response Received
3 company response(s)
Medium - date proximity
SEC wrote to company
2017-05-04
Esquire Financial Holdings, Inc.
Filing - SEC Comment Letter to Esquire Financial Holdings, Inc.
UPLOAD · 2017-05-04
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Company responded
2017-05-31
Esquire Financial Holdings, Inc.
References: May 4, 2017
Filing - Correspondence from Esquire Financial Holdings, Inc.
CORRESP · 2017-05-31
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Company responded
2017-06-22
Esquire Financial Holdings, Inc.
Filing - Correspondence from Esquire Financial Holdings, Inc.
CORRESP · 2017-06-22
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Company responded
2017-06-22
Esquire Financial Holdings, Inc.
Filing - Correspondence from Esquire Financial Holdings, Inc.
CORRESP · 2017-06-22
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Esquire Financial Holdings, Inc.
Awaiting Response
0 company response(s)
Medium
SEC wrote to company
2016-11-10
Esquire Financial Holdings, Inc.
Filing - SEC Comment Letter to Esquire Financial Holdings, Inc.
UPLOAD · 2016-11-10
Generating summary...
Summary
| Date | Type | Company | Location | File No | Link |
|---|---|---|---|---|---|
| 2026-05-04 | Company Response | Esquire Financial Holdings, Inc. | MD | N/A | Read Filing View |
| 2026-04-20 | SEC Comment Letter | Esquire Financial Holdings, Inc. | MD | 333-295076 | Read Filing View |
| 2024-04-30 | Company Response | Esquire Financial Holdings, Inc. | MD | N/A | Read Filing View |
| 2024-04-23 | SEC Comment Letter | Esquire Financial Holdings, Inc. | MD | 333-278832 | Read Filing View |
| 2021-06-07 | Company Response | Esquire Financial Holdings, Inc. | MD | N/A | Read Filing View |
| 2021-06-03 | SEC Comment Letter | Esquire Financial Holdings, Inc. | MD | N/A | Read Filing View |
| 2018-10-11 | SEC Comment Letter | Esquire Financial Holdings, Inc. | MD | N/A | Read Filing View |
| 2018-10-11 | Company Response | Esquire Financial Holdings, Inc. | MD | N/A | Read Filing View |
| 2017-06-22 | Company Response | Esquire Financial Holdings, Inc. | MD | N/A | Read Filing View |
| 2017-06-22 | Company Response | Esquire Financial Holdings, Inc. | MD | N/A | Read Filing View |
| 2017-05-31 | Company Response | Esquire Financial Holdings, Inc. | MD | N/A | Read Filing View |
| 2017-05-04 | SEC Comment Letter | Esquire Financial Holdings, Inc. | MD | N/A | Read Filing View |
| 2016-11-10 | SEC Comment Letter | Esquire Financial Holdings, Inc. | MD | N/A | Read Filing View |
| Date | Type | Company | Location | File No | Link |
|---|---|---|---|---|---|
| 2026-04-20 | SEC Comment Letter | Esquire Financial Holdings, Inc. | MD | 333-295076 | Read Filing View |
| 2024-04-23 | SEC Comment Letter | Esquire Financial Holdings, Inc. | MD | 333-278832 | Read Filing View |
| 2021-06-03 | SEC Comment Letter | Esquire Financial Holdings, Inc. | MD | N/A | Read Filing View |
| 2018-10-11 | SEC Comment Letter | Esquire Financial Holdings, Inc. | MD | N/A | Read Filing View |
| 2017-05-04 | SEC Comment Letter | Esquire Financial Holdings, Inc. | MD | N/A | Read Filing View |
| 2016-11-10 | SEC Comment Letter | Esquire Financial Holdings, Inc. | MD | N/A | Read Filing View |
| Date | Type | Company | Location | File No | Link |
|---|---|---|---|---|---|
| 2026-05-04 | Company Response | Esquire Financial Holdings, Inc. | MD | N/A | Read Filing View |
| 2024-04-30 | Company Response | Esquire Financial Holdings, Inc. | MD | N/A | Read Filing View |
| 2021-06-07 | Company Response | Esquire Financial Holdings, Inc. | MD | N/A | Read Filing View |
| 2018-10-11 | Company Response | Esquire Financial Holdings, Inc. | MD | N/A | Read Filing View |
| 2017-06-22 | Company Response | Esquire Financial Holdings, Inc. | MD | N/A | Read Filing View |
| 2017-06-22 | Company Response | Esquire Financial Holdings, Inc. | MD | N/A | Read Filing View |
| 2017-05-31 | Company Response | Esquire Financial Holdings, Inc. | MD | N/A | Read Filing View |
2026-05-04 - CORRESP - Esquire Financial Holdings, Inc.
CORRESP 1 filename1.htm Esquire Financial Holdings, Inc. 100 Jericho Quadrangle Suite 100 Jericho, New York 11753 May 4, 2026 Via Edgar Securities and Exchange Commission 100 F Street, N.E. Washington, D.C. 20549 Re: Esquire Financial Holdings, Inc. Registration Statement on Form S-4 (Registration No. 333-295076) Request for Acceleration of Effectiveness Ladies and Gentlemen: Esquire Financial Holdings, Inc., a Maryland corporation (the "Company"), hereby requests that the above-referenced Registration Statement on Form S-4 be declared effective at 10:00 a.m., Eastern time, on May 6, 2026, or as soon thereafter as is practicable. Very truly yours, /s/ Andrew C. Sagliocca Andrew C. Sagliocca Vice Chairman, Chief Executive Officer and President (Duly Authorized Representative)
2026-04-20 - UPLOAD - Esquire Financial Holdings, Inc. File: 333-295076
<DOCUMENT> <TYPE>TEXT-EXTRACT <SEQUENCE>2 <FILENAME>filename2.txt <TEXT> April 20, 2026 Andrew C. Sagliocca Chief Executive Officer Esquire Financial Holdings, Inc. 100 Jericho Quadrangle Suite 100 Jericho, NY 11753 Re: Esquire Financial Holdings, Inc. Registration Statement on Form S-4 Filed April 15, 2026 File No. 333-295076 Dear Andrew C. Sagliocca: This is to advise you that we have not reviewed and will not review your registration statement. Please refer to Rules 460 and 461 regarding requests for acceleration. 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. Please contact Robert Arzonetti at 202-551-8819 with any questions. Sincerely, Division of Corporation Finance Office of Finance cc: Marc Levy </TEXT> </DOCUMENT>
2024-04-30 - CORRESP - Esquire Financial Holdings, Inc.
CORRESP
1
filename1.htm
ESQUIRE FINANCIAL HOLDINGS, INC.
100 Jericho Quadrangle, Suite 100
Jericho, New York 11753
April 30, 2024
Via Edgar
Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549
Re: Esquire Financial Holdings, Inc.
Registration Statement on Form S-3 (Registration No. 333-278832)
Request for Acceleration of Effectiveness
Ladies and Gentlemen:
Esquire Financial Holdings, Inc., a Maryland corporation (the “Company”), hereby requests that the Company's above-referenced Registration
Statement on Form S-3 be declared effective at 2:00 p.m., Eastern Time, on May 2, 2024, or as soon thereafter as is practicable.
Very truly yours,
/s/ Andrew C. Sagliocca
Andrew C. Sagliocca
Vice Chairman, President and Chief Executive Officer
(Duly Authorized Representative)
2024-04-23 - UPLOAD - Esquire Financial Holdings, Inc. File: 333-278832
United States securities and exchange commission logo
April 23, 2024
Andrew C. Sagliocca
Vice Chairman, CEO and President
Esquire Financial Holdings, Inc.
100 Jericho Quadrangle, Suite 100
Jericho, NY 11753
Re:Esquire Financial Holdings, Inc.
Registration Statement on Form S-3
Filed April 19, 2024
File No. 333-278832
Dear Andrew C. Sagliocca:
This is to advise you that we have not reviewed and will not review your registration
statement.
Please refer to Rules 460 and 461 regarding requests for acceleration. 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.
Please contact Madeleine Joy Mateo at 202-551-3465 with any questions.
Sincerely,
Division of Corporation Finance
Office of Finance
cc: Gregory M. Sobczak, Esq.
2021-06-07 - CORRESP - Esquire Financial Holdings, Inc.
CORRESP
1
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ESQUIRE
FINANCIAL HOLDINGS, INC.
100 Jericho Quadrangle,
Suite 100
Jericho, New York
11753
June 7, 2021
Via Edgar
Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549
Re:
Esquire Financial Holdings, Inc.
Registration Statement on Form S-3 (Registration No. 333-256678)
Request for Acceleration of Effectiveness
Ladies and Gentlemen:
Esquire
Financial Holdings, Inc., a Maryland corporation (the “Company”), hereby requests that the Company's above-referenced Registration
Statement on Form S-3 be declared effective at 2:00 p.m., Eastern Time, on June 9, 2021, or as soon thereafter as is practicable.
Very truly yours,
/s/ Andrew C. Sagliocca
Andrew C. Sagliocca
President and Chief Executive Officer
(Duly Authorized Representative)
2021-06-03 - UPLOAD - Esquire Financial Holdings, Inc.
United States securities and exchange commission logo
June 3, 2021
Andrew Sagliocca
President and Chief Executive Officer
Esquire Financial Holdings, Inc.
100 Jericho Quadrangle, Suite 100
Jericho, NY 11753
Re:Esquire Financial Holdings, Inc.
Registration Statement on Form S-3
Filed June 1, 2021
File No. 333-256678
Dear Mr. Sagliocca:
This is to advise you that we have not reviewed and will not review your registration
statement.
Please refer to Rules 460 and 461 regarding requests for acceleration. 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.
Please contact Eric Envall at (202) 551-3234 with any questions.
Sincerely,
Division of Corporation Finance
Office of Finance
2018-10-11 - UPLOAD - Esquire Financial Holdings, Inc.
October 10, 2018
Andrew Sagliocca
President and Chief Executive Officer
Esquire Financial Holdings, Inc.
100 Jericho Quadrangle, Suite 100
Jericho, NY 11753
Re:Esquire Financial Holdings, Inc.
Registration Statement on Form S-3
Filed October 5, 2018
File No. 333-227725
Dear Mr. Sagliocca:
This is to advise you that we have not reviewed and will not review your registration
statement.
Please refer to Rules 460 and 461 regarding requests for acceleration. 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.
Please contact Eric Envall at (202) 551-3234 with any questions.
Sincerely,
Division of Corporation Finance
Office of Financial Services
2018-10-11 - CORRESP - Esquire Financial Holdings, Inc.
CORRESP
1
filename1.htm
ESQUIRE FINANCIAL
HOLDINGS, INC.
100 Jericho Quadrangle,
Suite 100
Jericho, New York 11753
October 11, 2018
Via Edgar
Securities and Exchange
Commission
100 F Street, N.E.
Washington, D.C. 20549
Re: Esquire
Financial Holdings, Inc.
Registration
Statement on Form S-3 (Registration No. 333-227725)
Request for Acceleration of Effectiveness
Ladies and Gentlemen:
Esquire
Financial Holdings, Inc., a Maryland corporation (the “Company”), hereby requests that the Company's above-referenced
Registration Statement on Form S-3 be declared effective at 4:00 p.m., Eastern Time, on October 17, 2018, or as soon thereafter
as is practicable.
Very truly yours,
/s/ Andrew C. Sagliocca
Andrew C. Sagliocca
President and Chief Executive Officer
(Duly Authorized Representative)
2017-06-22 - CORRESP - Esquire Financial Holdings, Inc.
CORRESP
1
filename1.htm
VIA EDGAR
June 22, 2017
Securities and Exchange Commission
Division of Corporate Finance
100 F Street, N.E.
Washington, DC 20549
Re: Esquire Financial Holdings, Inc.
Registration Statement on Form
S-1
Registration No. 333-218372
Ladies and Gentlemen:
Pursuant to Rule 461 under the Securities
Act of 1933, as amended (the “Securities Act”), the undersigned, as underwriter for Esquire Financial Holdings, Inc.
proposed initial public offering of its common stock, hereby joins Esquire Financial Holdings, Inc.’s request for acceleration
of the above-referenced Registration Statement, requesting acceleration of the effective date to 4:00 p.m. (Eastern time)
on Monday, June 26, 2017, or as soon thereafter as is practicable.
In accordance with Rule 460 under the
Securities Act, and in connection with the foregoing, please be advised that we have distributed approximately 600 copies of the
Preliminary Prospectus, dated June 19, 2017.
The undersigned confirms that they have complied with and will
continue to comply with, and that they have been informed by the participating underwriters and dealers that they have complied
with and will continue to comply with, Rule 15c2-8 under the Securities Exchange Act of 1934, as amended, in connection with the
above-referenced issue.
Very truly yours,
SANDLER O’NEILL & PARTNERS, L.P.
By:
Sandler O’Neill & Partners Corp.,
the sole general partner
By:
/s/ Britten L.
Cosgrove
Britten L. Cosgrove
Authorized Signatory
2017-06-22 - CORRESP - Esquire Financial Holdings, Inc.
CORRESP
1
filename1.htm
Esquire Financial Holdings, Inc.
100 Jericho Quadrangle, Suite 100
Jericho, New York 11753
June 22, 2017
Via Edgar
Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549
Re:
Esquire Financial Holdings, Inc.
Registration Statement on Form S-1 (Registration Number 333-218372)
Request for Acceleration of Effectiveness
Ladies and Gentlemen:
Esquire Financial Holdings, Inc., a Maryland
corporation (the “Company”), hereby requests that the Company’s Registration Statement on Form S-1 be declared
effective on June 26, 2017 at 4:00 pm, or as soon thereafter as is practicable.
Very truly yours,
/s/ Andrew C. Sagliocca
Andrew C. Sagliocca
President and Chief Executive Officer
2017-05-31 - CORRESP - Esquire Financial Holdings, Inc.
CORRESP
1
filename1.htm
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 E-MAIL
(202) 274-2001
jgorman@luselaw.com
May 31, 2017
Erin E. Martin
Special Counsel
Office of Financial Services
United States Securities and Exchange Commission
Washington, D.C. 20549
Re:
Esquire Financial Holdings, Inc.
Draft Registration Statement on Form S-1
Submitted April 12, 2017
CIK No. 0001531031
Dear Ms. Martin:
On behalf of Esquire Financial Holdings,
Inc., a Maryland corporation (the “Company”), we are publicly filing herewith a Registration Statement on Form S-1
(the “Public Filing”) via the Securities and Exchange Commission’s (the “Commission”) EDGAR system.
In this letter, we respond to the comments of the staff (the “Staff”) of the Division of Corporation Finance of the
Commission contained in the Staff’s letter dated May 4, 2017 (the “Comment Letter”) regarding the above-referenced
Draft Registration Statement submitted to the Commission on April 12, 2017.
The Public Filing also includes other changes
that are intended to update, clarify and render more complete the information contained therein, including updates to the financial
statements and disclosures to reflect the Company’s financial results as of and for the three months ended March 31, 2017.
Set forth below are the Company’s
responses to the comments in the Comment Letter. For the convenience of the Staff, the Company has restated in this letter each
of the comments in the Comment Letter and numbered each of the responses to correspond to the numbers of the comments. Capitalized
terms used but not defined herein have the meanings given to them in the Public Filing. All references to page numbers and
captions (other than those in the Staff’s comments) correspond to the page numbers and captions in the Public Filing.
Prospectus Summary
Our Competitive Strengths, page 3
1. We note your response to comment 4. Please further balance your disclosure regarding your
business and growth strategies as well as competitive strengths by providing a brief summary of the most significant risks that
your business faces in the Summary section.
Response: In response
to the Staff’s comment, the Company has included a brief summary of the most significant risks on page 7 of the Public
Filing.
Business
Lending Activities, page 69
2. Clarify the percentage of total loans represented by each of attorney consumer loans and real
estate loans.
Response: In response
to the Staff’s comment, the Company has clarified the percentage of total loans represented by each of attorney consumer
loans and real estate loans beginning on page 71 of the Public Filing.
* * *
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 do not hesitate to contact the undersigned at (202) 274-2001 or Gary Lax at (202) 274-2031.
Very truly yours,
/s/ John J. Gorman
cc:
Jessica Livingston, Esq.
William Schroeder, CPA
Amit Pande, CPA
Andrew C. Sagliocca, President and Chief Executive Officer
Gary Lax, Esq.
2017-05-04 - UPLOAD - Esquire Financial Holdings, Inc.
Mail Stop 4720
May 4, 2017
Andrew C. Sagliocca
President and Chief Executive Officer
Esquire Financial Holdings, Inc.
320 Old Country Road, Suite 101
Garden City, NY 11530
Re: Esquire Financial Holdings, Inc.
Amendment No. 1 to Draft Registration Statement on Form S -1
Submitted April 12, 2017
CIK No . 0001531031
Dear Ms. Sagliocca :
We have reviewed your amended draft registration statement and have the following
comments. In some of our comments, we may ask you to provide us with information so we
may better understand your disclosure.
Please respond to this letter by providing the requested information and either submitting
an amended draft registration statement or publicl y filing your registration statement on
EDGAR. If you do not believe our comments apply to your facts and circumstances or do not
believe an amendment is appropriate, please tell us why in your response.
After reviewing the information you provide in r esponse to these comments and your
amended draft registration statement or filed registration statement, we may have additional
comments.
Prospectus Summary
Our Competitive Strengths, page 3
1. We note your response to comment 4. Please further balance your disclosure regarding
your business and growth strategies as well as competitive strengths by providing a brief
summary of the most significant risks that your business faces in the Summary se ction.
Business
Lending Activities, page 69
2. Clarify the percentage of total loans represented by each of attorney consumer loans and
real estate loans.
Andrew C. Sagliocca
Esquire Financial Holdings, Inc.
May 4, 2017
Page 2
You may contact William Schroeder at 202-551-3294 or Amit Pande at 202-551-3423
if you have questions regarding comments on the financial statements and related matters.
Please contact Jessica Livingston at 202-551-3448 or me at 202-551-3391 with any other
questions.
Sincerely,
/s/ Erin E. Martin
Erin E. Martin
Special Counsel
Office of Financial Services
cc: John J. Gorman, Esq.
2016-11-10 - UPLOAD - Esquire Financial Holdings, Inc.
Mail Stop 4720 November 9, 2016 Via E -mail Andrew C. Sagliocca President and Chief Executive Officer Esquire Financial Holdings, Inc . 320 Old Country Road, Suite 101 Garden City, NY 11530 Re: Esquire Financial Holdings, Inc. Draft Registration Statement on Form S -1 Submitted October 13, 2016 CIK No. 0001531031 Dear Mr. Sagliocca : We have reviewed your draft registration statement and have the following comments. In some of our comments, we may ask you to provide us with information so we may better understand your disclos ure. Please respond to this letter by providing the requested information and either submitting an amended draft registration statement or publicly filing your registration statement on EDGAR. If you do not believe our comments apply to your facts and circumstances or do not believe an amendment is appropriate, please tell us why in your response. After reviewing the information you provide in response to these comments and your amended draft registration statement or filed registration statement, we may have additional comments. General 1. Please supplementally provide us with copies of all written communications, as defined in Rule 405 under the Securities Act, that you , or anyone authorized to do so on your behalf , present to potential investors in reliance on Section 5(d) of the Securities Act, whether or not they retain copies of the communications Andrew C. Sagliocca Esquire Financial Holdings, Inc . November 9, 2016 Page 2 Summary Our Company , page 1 2. In order to provide investors with a more balanced picture of your growth history and challenges, expand your discussion of your results over the last 6 month period to also capture th e results over the full fiscal years included in the financial statements. Similarly, please discuss the challenges, including credit exposure, from a growing and unseasoned loan portfolio. Our Business Strategy, page 2 3. Please tell us wh ether Esquire commissioned the Towers Watson report cited in this section. Also, balance your discussion of the growth in tort costs compared to GDP growth by also disclosing that over the last 5 years covered by the report, tort costs had lagged GDP growt h. Finally, please revise this section to clarify whether management has conducted any research to determine if the value of tort actions in 2010 remains indicati ve of the size of the tort actions in 2016. Our Competitive Strengths, page 3 4. The disclosure in the summary should be a balanced presentation of your business. Please balance the description of your competitive strengths with equally prominent disclosure of the challenges you face and the risks and limitations that could harm your business or inhibit your strategic plans. For example, and without limitation, please balance your discussion of your asset quality with a discussion of the added risks of targeting small and medium sized business es as loan clients. In this regard, we note your disclosure in the first three risk factors on page 11, which disclose that increasing commercial loans may increase credit risk and the commercial, multifamily real estate and attorney loans that comprise a substantial percentage of your loan portfolio have a higher degree of risk than other loan types . As another example, please balance your discussion with a discussion of the risks your business faces from business concentration in New York , as you discuss in the s econd risk factor on page 15 . Risk Fact ors Because we intend …increase our commercial loans, our credit risk will increase , page 11 5. Revise this risk factor to discuss, in detail, the specific credit risk challenges associated with your loans to attorneys as well as to law firm clients. Andrew C. Sagliocca Esquire Financial Holdings, Inc . November 9, 2016 Page 3 Our loan portfolio is unseasoned, page 14 6. Revise this risk factor to disclose the average age of the loans in each major lending category. As a community banking institutio n, we have lower lending limits …, page 17 7. Revise this risk factor to disclose your current lending limit, and indicate the aggregate number of loans that are at or within 10% of your current limit. Our management will have broad discretion as to the use of proceeds …, page 2 4 8. Revise this risk factor to disclose your current return on equity, your current equity position as well as your expected equity position after the offering. Use of Proceeds, page 29 9. We note your disclosure on page 23 that your return on equity may decline as a res ult of the proceeds from the offering. We also note that you already have a significant amount of capital. Please revise this section to explain all the specific reasons that you chose to make an offering at this time. For instance, how much will your l ending limit increase as a result of your increased capital? Please refer to Item 504 of Regulation S -K. 10. We note that you anticipate using net proceeds to explore acquisition opportunities. Please also give a brief description of any acquisition strategy, including the types of opportunities you intend to explore , or clarify that management has not yet determined the types of businesses that you might target . Consider revisions to your management ’s discussion and analysis based o n your response. Business Merchant Services Activities, page 66 11. Revise this section to explain, in more detail, your merchant servicing operations. For instance, how much in revenue do you generate from your $300 million in payment volume. Also, since you note that the independent servicin g organization model represents a lower risk profile due to merchant reserves, please discuss how you determine the size of the merchant reserves, as well as the risks associated with the direct merchant model. Also, please disclose the payment processing system that you access for your clients, and your contractual arrangements with that network. Credit Risk Management, page 70 Andrew C. Sagliocca Esquire Financial Holdings, Inc . November 9, 2016 Page 4 12. Revise your discussion regarding settlement loans to discuss your underwriting procedure to determine the value of a settlement and the potential time until the settlement is paid. Also, please discuss your monitoring process to determine when a settlement has been paid and any protections you have to ensure that a settlement is not renegotiated after you have made the loan. Competitors, page 73 13. Revise this section , as well as your discussion regarding competition in the risk factors, to discuss whether you face competition with other banks or other lenders t o fund lawyers or to provide financing for legal clients awaiting settlement payments. Management The Business Background of Our Directors and Executive Officers, page 84 14. In order for investors to evaluate the management of a public company, Item 401(e) o f Regulation S -K requires that you disclose the business experience of your officers and directors . Please revise your disclosure to state the date each director and executive officer began their current occupation or otherwise expand to include specific business experience for the past five years. For instance, how long has Mr. Kornhaber been director of sa les for Esquire? Si milarly, please clarify whether Mr. Deutsch has managed his family office , or if Mr. Herman managed his law firm for the five y ear period . Description of Capital Stock, page 99 15. We note your disclosure in the introductory paragraph that the description appearing in this section “does not purport to be a complete description of these rights and may not contain all of the information regarding our capital stock that is important to you. These rights can be determined in full only by reference to federal and state banking laws and regulations, the Maryland General Corporation Code….” Remove this language and revise your disclosure to provide a complete description of the material rights of your capital stock. Andrew C. Sagliocca Esquire Financial Holdings, Inc . November 9, 2016 Page 5 You may contact William Schroeder at 202-551-3294 or Amit Pande at 202-551-3423 if you have questions regarding comments on the financial statements and related matters. Please contact Jessica Livingston at 202-551-3448 or me at 202-551-3419 with any other questions. Sincerely, /s/ Christian Windsor Christian Windsor Special Counsel Office of Financial Services cc: John J. Gorman , Esq. (Via E -mail)
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