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NB Bancorp, Inc.
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NB Bancorp, Inc.
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SEC wrote to company
2023-07-06
NB Bancorp, Inc.
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2023-07-27
NB Bancorp, Inc.
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2023-08-08
NB Bancorp, Inc.
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2023-10-10
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2023-10-10
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2023-08-01
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| Date | Type | Company | Location | File No | Link |
|---|---|---|---|---|---|
| 2025-07-28 | Company Response | NB Bancorp, Inc. | N/A | N/A | Read Filing View |
| 2025-07-10 | SEC Comment Letter | NB Bancorp, Inc. | N/A | 333-288494 | Read Filing View |
| 2023-10-10 | Company Response | NB Bancorp, Inc. | N/A | N/A | Read Filing View |
| 2023-10-10 | Company Response | NB Bancorp, Inc. | N/A | N/A | Read Filing View |
| 2023-08-08 | Company Response | NB Bancorp, Inc. | N/A | N/A | Read Filing View |
| 2023-08-01 | SEC Comment Letter | NB Bancorp, Inc. | N/A | N/A | Read Filing View |
| 2023-07-27 | Company Response | NB Bancorp, Inc. | N/A | N/A | Read Filing View |
| 2023-07-06 | SEC Comment Letter | NB Bancorp, Inc. | N/A | N/A | Read Filing View |
| Date | Type | Company | Location | File No | Link |
|---|---|---|---|---|---|
| 2025-07-10 | SEC Comment Letter | NB Bancorp, Inc. | N/A | 333-288494 | Read Filing View |
| 2023-08-01 | SEC Comment Letter | NB Bancorp, Inc. | N/A | N/A | Read Filing View |
| 2023-07-06 | SEC Comment Letter | NB Bancorp, Inc. | N/A | N/A | Read Filing View |
| Date | Type | Company | Location | File No | Link |
|---|---|---|---|---|---|
| 2025-07-28 | Company Response | NB Bancorp, Inc. | N/A | N/A | Read Filing View |
| 2023-10-10 | Company Response | NB Bancorp, Inc. | N/A | N/A | Read Filing View |
| 2023-10-10 | Company Response | NB Bancorp, Inc. | N/A | N/A | Read Filing View |
| 2023-08-08 | Company Response | NB Bancorp, Inc. | N/A | N/A | Read Filing View |
| 2023-07-27 | Company Response | NB Bancorp, Inc. | N/A | N/A | Read Filing View |
2025-07-28 - CORRESP - NB Bancorp, Inc.
CORRESP 1 filename1.htm July 28, 2025 VIA EDGAR U.S. Securities and Exchange Commission Division of Corporation Finance 100 F Street, N.E. Washington, D.C. 20549 Attention: Susan Block ( blocks@sec.gov ) Re: NB Bancorp, Inc. Registration Statement on Form S-4 CIK No. 0001979330 File No. 333-288494 Request for Acceleration Ladies and Gentlemen: Reference is made to the Registration Statement on Form S-4 (File No. 333-288494) filed by NB Bancorp, Inc. (the " Company ") with the U.S. Securities and Exchange Commission (the " Commission ") on July 2, 2025, as amended (the " Registration Statement "). The Company hereby requests that the Registration Statement be made effective at 8:00 a.m. Eastern Time on Wednesday, July 30, 2025, or as soon as possible thereafter, in accordance with Rule 461 of the General Rules and Regulations promulgated under the U.S. Securities Exchange Act of 1933, as amended. Please contact Michael K. Krebs of Nutter, McClennen & Fish, LLP at (617) 439-2288 or by email at mkrebs@nutter.com with any questions you may have concerning this request. Please notify Mr. Krebs when this request for acceleration has been granted. Sincerely, NB BANCORP, INC. By: /s/ Joseph P. Campanelli Name: Joseph P. Campanelli Its: President and Chief Executive Officer 1063 Great Plain Avenue | Needham, MA 02492 | NBBancorp.com
2025-07-10 - UPLOAD - NB Bancorp, Inc. File: 333-288494
<DOCUMENT> <TYPE>TEXT-EXTRACT <SEQUENCE>2 <FILENAME>filename2.txt <TEXT> July 10, 2025 Joseph Campanelli Chief Executive Officer NB Bancorp, Inc. 1063 Great Plain Avenue Needham, Massachusetts 02492 Re: NB Bancorp, Inc. Registration Statement on Form S-4 Filed July 2, 2025 File No. 333-288494 Dear Joseph Campanelli: 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 Susan Block at 202-551-3210 with any questions. Sincerely, Division of Corporation Finance Office of Finance </TEXT> </DOCUMENT>
2023-10-10 - CORRESP - NB Bancorp, Inc.
CORRESP
1
filename1.htm
NB Bancorp, Inc.
1063 Great Plain Avenue
Needham, Massachusetts 02492
October 10, 2023
Via Edgar
Securities and Exchange Commission
100 F Street, N.E.
Washington,
D.C. 20549
Re: NB Bancorp, Inc.
Registration Statement on Form S-1 (Registration Number
333-272567)
Request for Acceleration of Effectiveness
Ladies and Gentlemen:
NB Bancorp, Inc., a Maryland corporation (the “Company”),
hereby requests that the Company’s Registration Statement on Form S-1 be declared effective on October 12, 2023 at 10:00 a.m., or
as soon thereafter as is practicable.
The Company hereby acknowledges that:
· should the Commission or the staff, acting pursuant to delegated authority, declare the filing effective, it does not foreclose the
Commission from taking any action with respect to the filing;
· the action of the Commission or the staff, acting pursuant to delegated authority, in declaring the filing effective, does not relieve
the Company from its full responsibility for the adequacy and accuracy of the disclosure in the filing; and
· the Company may not assert this action as a defense in any proceeding initiated by the Commission or any person under the federal
securities laws of the United States.
Very truly yours,
/s/ Joseph P. Campanelli
Joseph P. Campanelli
President and Chief Executive Officer
2023-10-10 - CORRESP - NB Bancorp, Inc.
CORRESP
1
filename1.htm
October 10, 2023
Via
Edgar
Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549
Re: NB Bancorp, Inc.
Registration Statement on Form S-1 (Registration Number
333- 272567)
Request for Acceleration of Effectiveness
Ladies and Gentlemen:
In accordance with Rule 461 of Regulation
C promulgated under the Securities Act of 1933, we hereby join NB Bancorp, Inc. in requesting that the effective date of the above-referenced
Registration Statement be accelerated so that it will become effective at 10:00 a.m. on October 12, 2023 or as soon thereafter
as may be practicable.
PIPER SANDLER & CO.
By:
/s/ Derek Szot
Name: Derek Szot
Title: Managing Director
2023-08-08 - CORRESP - NB Bancorp, 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) 274-2004
slanter@luselaw.com
August 8, 2023
Via
EDGAR
Securities and Exchange Commission
Division of Corporation Finance
Washington, D.C. 20549-3561
Attn: Ms. Aisha Adegbuyi, Staff Attorney
Re:
NB Bancorp, Inc.
Registration Statement on Form S-1 (File No. 333-272567)
Dear Ms. Adegbuyi:
On behalf of NB Bancorp, Inc. (the “Registrant”)
and in accordance with Rule 101 of Regulation S-T, we are hereby transmitting Pre-Effective Amendment No. 2 to the Registrant’s
Registration Statement on Form S-1 (the “Amended Form S-1”). Set forth below are the comments from the Staff’s letter
dated August 1, 2023, as well as the Registrant’s responses to those comments. The Amended Form S-1 has been blacklined to reflect
changes from the initial filing.
Form S-1/A filed July 27, 2023
Business of Needham Bank
Sources of Funds, page 111
1. Please revise to disclose the outstanding amount of time deposits that are uninsured at the end of the latest reported period by
time remaining until maturity. Refer to Item 1 406(f)(2) of Regulation S-K.
The disclosure on page 112 of the prospectus has been revised
in response to the comment.
We supplementally advise the staff that all of Needham
Bank’s deposits are fully insured due to the additional insurance provided to a participating Massachusetts bank, such as
Needham Bank, under the DIF, a private industry-sponsored insurance fund in Massachusetts that insures all deposits at Needham Bank
above FDIC limits.
LUSE GORMAN, PC
Ms. Aisha Adegbuyi
Securities and Exchange Commission
August 8, 2023
Page 2
Additionally, pursuant to Regulation S-K 1406(f)(2), we supplementally
advise the Staff that Needham Bank has no time deposits that are otherwise uninsured (including for example, U.S. time deposits in uninsured
accounts, non-U.S. time deposits in uninsured accounts, or non-U.S. time deposits in excess of any country-specific insurance fund limit).
Regulation S-K 1406(f)(2).
Consolidated Financial Statements of NB Financial, MHC and Subsidiary
Note 5 – Mortgage Banking – Loan Sales and Servicing,
page F-68
2. Please refer to comment 11. We note that the carrying value of your mortgage servicing rights disclosed on page F-68 is the same
amount as the fair value disclosed on page F-83. We also note your policy on page F-53 which states: “For subsequently measuring
and reporting servicing assets, the Company has chosen to use the amortization method, rather than the fair value measurement method."
Please tell us how you determined that the fair value of your mortgage servicing rights was equivalent to their carrying value at each
reporting period presented in the financial statements.
The disclosure on pages F-33 and F-83 have been revised
to include the fair value instead of the carrying value.
* * *
We request that the staff advise the undersigned
at slanter@luselaw.com or at (202) 274-2004 as soon as possible if it has any further comments.
Respectfully,
/s/Steven Lanter
Steven Lanter
cc: Joseph P. Campanelli, President and Chief Executive Officer
Lawrence M. F. Spaccasi, Esq.
2023-08-01 - UPLOAD - NB Bancorp, Inc.
United States securities and exchange commission logo
August 1, 2023
Joseph Campanelli
President, Chief Executive Officer
NB Bancorp, Inc.
1063 Great Plain Avenue,
Needham, Massachusetts 02492
Re:NB Bancorp, Inc.
Amendment No. 1 to Registration Statement on Form S-1
Filed July 27, 2023
File No. 333-272567
Dear Joseph Campanelli:
We have reviewed your amended 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 amending your registration statement and providing the
requested information. 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 any amendment to your registration statement and the information you
provide in response to these comments, we may have additional comments.
Form S-1/A filed on July 27, 2023
Business of Needham Bank
Sources of Funds, page 111
1.Please revise to disclose the outstanding amount of time deposits that are uninsured at the
end of the latest reported period by time remaining until maturity. Refer to Item
1406(f)(2) of Regulation S-K.
Consolidated Financial Statements of NB Financial, MHC and Subsidiary
Note 5 – Mortgage Banking – Loan Sales and Servicing, page F-68
2.Please refer to comment 11. We note that the carrying value of your mortgage servicing
rights disclosed on page F-68 is the same amount as the fair value disclosed on page F-
83. We also note your policy on page F-53 which states: "For subsequently measuring
FirstName LastNameJoseph Campanelli
Comapany NameNB Bancorp, Inc.
August 1, 2023 Page 2
FirstName LastName
Joseph Campanelli
NB Bancorp, Inc.
August 1, 2023
Page 2
and reporting servicing assets, the Company has chosen to use the amortization method,
rather than the fair value measurement method." Please tell us how you determined that
the fair value of your mortgage servicing rights was equivalent to their carrying value at
each reporting period presented in the financial statements.
You may contact Katharine Garrett at 202-551-2332 or William Schroeder at 202-551-
3294 if you have questions regarding comments on the financial statements and related
matters. Please contact Aisha Adegbuyi at 202-551-8754 or Christian Windsor at 202-551-
3419 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Finance
cc: Steven Lanter
2023-07-27 - CORRESP - NB Bancorp, 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) 274-2004
slanter@luselaw.com
July 27, 2023
Via
EDGAR
Securities and Exchange Commission
Division of Corporation Finance
Washington, D.C. 20549-3561
Attn:
Ms. Aisha Adegbuyi, Staff Attorney
Re: NB Bancorp, Inc.
Registration Statement
on Form S-1 (File No. 333-272567)
Dear Ms. Adegbuyi:
On behalf of NB Bancorp, Inc. (the “Registrant”)
and in accordance with Rule 101 of Regulation S-T, we are hereby transmitting Pre-Effective Amendment No. 1 to the Registrant’s
Registration Statement on Form S-1 (the “Amended Form S-1”). Set forth below are the comments from the Staff’s letter
dated July 6, 2023, as well as the Registrant’s responses to those comments. The Amended Form S-1 has been blacklined to reflect
changes from the initial filing.
Form S-1 filed June 9, 2023
Risk Factors
Our portfolio of commercial real estate loans and commercial
and industrial loans...involve credit risks..., page 17
1. We note your statement regarding your lending activities that "[s]uch loans typically involve larger loan balances to single
borrowers or groups of related borrowers compared to one- to four-family residential mortgage loans. In addition, the repayment of these
types of loans depends on the successful management and operation of the borrower’s businesses or properties." Revise this
risk factor to state your current loan to one borrower limit, as well as the amounts of your four largest customer relationships as of
a recent date.
The disclosure on page 17 has been revised
in response to the comment.
LUSE GORMAN, PC
Ms. Aisha Adegbuyi
Securities and Exchange Commission
July 27, 2023
Page 2
The geographic concentration of our loan portfolio and lending
activities, page 19
2. Revise this risk factor to discuss, as appropriate, the factors that impact the current Greater Boston commercial real estate market.
For instance, discuss any changes in occupancy for office, industrial or retail real estate.
The disclosure on page 19 has been revised
in response to the comment.
Uncertainty about the future of the London Interbank Offered
Rate, or "LIBOR," may adversely affect our business, page 22
3. Please disclose to what extent your existing loans, deposits, and other financial instruments, including your existing swap contracts,
have interest rates that are set by reference to LIBOR. For each significant asset or liability that is currently priced based on reference
to LIBOR, clarify whether you have evaluated whether the contractual language will permit conversion to a new reference rate.
The disclosure on page 22 has been revised
in response to the comment.
The fair value of our investment securities can fluctuate, page
26
4. Revise this risk factor to disclose recent experience with unrealized gains or losses on your securities portfolio.
The disclosure on page 27 has been revised in
response to the comment.
Risks Related to Our Funding, page 27
5. Revise this section to discuss the impact on your ability to utilize both FHLB borrowings and/or brokered deposits in the event
that your capital position declined below "well capitalized" or if your net tangible equity were to decline.
The disclosure on page 28 has been revised
in response to the comment.
LUSE GORMAN, PC
Ms. Aisha Adegbuyi
Securities and Exchange Commission
July 27, 2023
Page 3
Management of Market Risk, page 75
6. We note your statement that the "Asset Liability Committee is responsible for managing market risk." Please revise this
section, or another appropriate section, to discuss the membership of the Asset Liability Committee. Disclose whether the committee reports
to the Board or any of the four standing committees of the Board.
The disclosure on page 84 has been revised
in response to the comment.
Competition, page 84
7. You note that since 2017 you have expanded, and intend to continue to expand, into commercial and industrial lending. Please disclose
whether you compete with particular larger and/or more well-established competitors in this segment of your lending operations. If there
are dominant competitors in a key market segment, revise this section to identify those competitors. Discuss the extent to which the ability
to compete in this area is dependent on existing relationships, and how this might impact your business strategy to focus in the commercial
and industrial lending areas. Make appropriate changes to your management's discussion and/or risk factors based on your response.
The disclosure on page 93 has been revised
in response to the comment.
Business of Needham Bank
Sources of Funds, page 103
8. Revise this section to clarify whether NB Bancorp will continue to offer full insurance coverage for its deposits from the DIF
after the conversion of Needham Bank from a cooperative bank charter.
The disclosure on page 113 has been revised in response
to the comment.
9. Revise your discussion of your deposits to note whether your depositors have any significant concentrations among your depositors,
particularly for your larger deposit accounts. For example, disclose any deposits focused in the tech industry, venture capital funds
or portfolio companies, or out of market firms.
The disclosure on page 112 has been revised
in response to the comment.
LUSE GORMAN, PC
Ms. Aisha Adegbuyi
Securities and Exchange Commission
July 27, 2023
Page 4
Management of NB Bancorp
The Business Background of Our Directors and Executive Officers,
page 121
10. Please revise the business background information for Mr.
Orfanello to confirm that his position as partner at One Rock Capital began more than five years ago. Alternatively, please revise to
provide a complete description of his business experience in the last five years. Refer to Item 401(e)(1) of Regulation S-K.
The disclosure on page 131 of the prospectus
has been revised in response to the comment.
Consolidated Financial Statements of NB Financial, MHC and Subsidiary
Note 5 – Mortgage Banking – Loan Sales and Servicing,
page F-68
11. We note your disclosure on page F-68 that the carrying value
of mortgage servicing rights exceeded their fair value at December 31, 2022, and that no adjustment for impairment was recognized. Please
tell us and revise to clarify if the “balance at the end of year” in the table on page F-68 is the carrying value or fair
value of your mortgage servicing rights. In addition, please tell us how you determined that an impairment was not necessary given that
the carrying value exceeded fair value. Please refer to ASC 860-50-35-9.
The disclosure on page F-68 of the prospectus
has been revised in response to the comment to clarify that the fair value of mortgage servicing rights exceeded the carrying value. As
such, an impairment was not necessary.
Exhibits
12. Both exhibit 10.1 and 10.2,
the employment agreements between Needham Bank and Messrs. Campanelli and Rinaldi respectively, were effective through January1, 2023.
On page 126, you indicate that Needham Bank has entered into new employment agreements that expire in 2026 and 2025 respectively. Please
include the new agreements as exhibits in your next amendment.
We note the Staff’s comment and supplementally confirm
that the employment agreements which have been filed as Exhibit 10.1 and 10.2 are the same employment agreements referenced on page 126
of the prospectus.
The language of the employment agreement with Mr.
Campanelli (Exhibit 10.1) provides that the agreement will become effective as of the date the parties execute the agreement and
will continue through January 1, 2023, unless terminated earlier pursuant to Section 5 of the agreement (the
“Term”). The agreement also provides that commencing on January 1, 2021, and on each January 1 thereafter
(each, a “Renewal Date”), the Term shall extend automatically for one (1) additional year, so that the Term shall
be three (3) years from such Renewal Date, unless either the Bank or the Executive provides written notice to the other Party
at least ninety (90) days prior to such Renewal Date notifying the other Party of his or its election to not renew this
Agreement.
LUSE GORMAN, PC
Ms. Aisha Adegbuyi
Securities and Exchange Commission
July 27, 2023
Page 5
The language of the employment agreement with Mr. Rinaldi
provides that the agreement will become effective as of the date the parties execute the agreement and will continue through January 1,
2022, unless terminated earlier pursuant to Section 5 of the agreement (the “Term”). The agreement also provides that
commencing on January 1, 2021, and on each January 1 thereafter (each, a “Renewal Date”), the Term shall extend
automatically for one (1) additional year, so that the Term shall be two (2) years from such Renewal Date, unless either the
Bank or the Executive provides written notice to the other Party at least ninety (90) days prior to such Renewal Date notifying the other
Party of his or its election to not renew this Agreement.
The following disclosure in the prospectus references the
current terms of the employment agreements, as extended pursuant to the terms of the agreements. New agreements were not entered
into by the parties.
“Needham Bank has entered into employment agreements
with Messrs. Campanelli and Rinaldi. The term of the employment agreement with Mr. Campanelli is three years, currently expiring on January
1, 2026, and the term of the employment agreement with Mr. Rinaldi is two years, currently expiring on January 1, 2025. The terms of the
employment agreements automatically extend on each January 1st (the “Renewal Date”) for one year, so that the term again becomes
either three years (in the case of Mr. Campanelli) or two years (in the case of Mr. Rinaldi), unless either Needham Bank or the executive
provides written notice to the other party at least 90 days prior to the Renewal Date notifying the other party of his or its election
not to renew the term of the employment agreement.”
* * *
We request that the staff advise the undersigned
at slanter@luselaw.com or at (202) 274-2004 as soon as possible if it has any further comments.
Respectfully,
/s/Steven Lanter
Steven Lanter
cc: Joseph P. Campanelli, President and Chief Executive Officer
Lawrence M. F. Spaccasi, Esq.
2023-07-06 - UPLOAD - NB Bancorp, Inc.
United States securities and exchange commission logo
July 6, 2023
Joseph Campanelli
President, Chief Executive Officer
NB Bancorp, Inc.
1063 Great Plain Avenue
Needham, Massachusetts 02492
Re:NB Bancorp, Inc.
Registration Statement on Form S-1
Filed June 9, 2023
File No. 333-272567
Dear Joseph Campanelli:
We have reviewed your 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 amending your registration statement and providing the
requested information. 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 any amendment to your registration statement and the information you
provide in response to these comments, we may have additional comments.
Form S-1 filed June 9, 2023
Risk Factors
Our portfolio of commercial real estate loans and commercial and industrial loans...involve
credit risks..., page 17
1.We note your statement regarding your lending activities that "[s]uch loans typically
involve larger loan balances to single borrowers or groups of related borrowers compared
to one- to four-family residential mortgage loans. In addition, the repayment of these
types of loans depends on the successful management and operation of the borrower’s
businesses or properties." Revise this risk factor to state your current loan to one
borrower limit, as well as the amounts of your four largest customer relationships as of a
recent date.
FirstName LastNameJoseph Campanelli
Comapany NameNB Bancorp, Inc.
July 6, 2023 Page 2
FirstName LastNameJoseph Campanelli
NB Bancorp, Inc.
July 6, 2023
Page 2
The geographic concentration of our loan portfolio and lending activities, page 19
2.Revise this risk factor to discuss, as appropriate, the factors that impact the current Greater
Boston commercial real estate market. For instance, discuss any changes in occupancy for
office, industrial or retail real estate.
Uncertainty about the future of the London Interbank Offered Rate, or "LIBOR," may adversely
affect our business, page 22
3.Please disclose to what extent your existing loans, deposits, and other financial
instruments, including your existing swap contracts, have interest rates that are set by
reference to LIBOR. For each significant asset or liability that is currently priced based
on reference to LIBOR, clarify whether you have evaluated whether the contractual
language will permit conversion to a new reference rate.
The fair value of our investment securities can fluctuate, page 26
4.Revise this risk factor to disclose recent experience with unrealized gains or losses on
your securities portfolio.
Risks Related to Our Funding, page 27
5.Revise this section to discuss the impact on your ability to utilize both FHLB borrowings
and/or brokered deposits in the event that your capital position declined below "well
capitalized" or if your net tangible equity were to decline.
Management of Market Risk, page 75
6.We note your statement that the "Asset Liability Committee is responsible for managing
market risk." Please revise this section, or another appropriate section, to discuss the
membership of the Asset Liability Committee. Disclose whether the committee reports to
the Board or any of the four standing committees of the Board.
Competition, page 84
7.You note that since 2017 you have expanded, and intend to continue to expand, into
commercial and industrial lending. Please disclose whether you compete with particular
larger and/or more well-established competitors in this segment of your lending
operations. If there are dominant competitors in a key market segment, revise this section
to identify those competitors. Discuss the extent to which the ability to compete in this
area is dependent on existing relationships, and how this might impact your business
strategy to focus in the commercial and industrial lending areas. Make appropriate
changes to your management's discussion and/or risk factors based on your response.
FirstName LastNameJoseph Campanelli
Comapany NameNB Bancorp, Inc.
July 6, 2023 Page 3
FirstName LastNameJoseph Campanelli
NB Bancorp, Inc.
July 6, 2023
Page 3
Business of Needham Bank
Sources of Funds, page 103
8.Revise this section to clarify whether NB Bancorp will continue to offer full insurance
coverage for its deposits from the DIF after the conversion of Needham Bank from a
cooperative bank charter.
9.Revise your discussion of your deposits to note whether your depositors have any
significant concentrations among your depositors, particularly for your larger deposit
accounts. For example, disclose any deposits focused in the tech industry, venture capital
funds or portfolio companies, or out of market firms.
Management of NB Bancorp
The Business Background of Our Directors and Executive Officers, page 121
10.Please revise the business background information for Mr. Orfanello to confirm that his
position as partner at One Rock Capital began more than five years ago. Alternatively,
please revise to provide a complete description of his business experience in the last five
years. Refer to Item 401(e)(1) of Regulation S-K.
Consolidated Financial Statements of NB Financial, MHC and Subsidiary
Note 5 – Mortgage Banking – Loan Sales and Servicing, page F-68
11.We note your disclosure on page F-68 that the carrying value of mortgage servicing rights
exceeded their fair value at December 31, 2022, and that no adjustment for impairment
was recognized. Please tell us and revise to clarify if the “balance at the end of year” in
the table on page F-68 is the carrying value or fair value of your mortgage servicing
rights. In addition, please tell us how you determined that an impairment was not
necessary given that the carrying value exceeded fair value. Please refer to ASC 860-50-
35-9.
Exhibits
12.Both exhibit 10.1 and 10.2, the employment agreements between Needham Bank and
Messrs. Campanelli and Rinaldi respectively, were effective through January1, 2023. On
page 126, you indicate that Needham Bank has entered into new employment agreements
that expire in 2026 and 2025 respectively. Please include the new agreements as exhibits
in your next amendment.
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.
Refer to Rules 460 and 461 regarding requests for acceleration. Please allow adequate
time for us to review any amendment prior to the requested effective date of the registration
statement.
FirstName LastNameJoseph Campanelli
Comapany NameNB Bancorp, Inc.
July 6, 2023 Page 4
FirstName LastName
Joseph Campanelli
NB Bancorp, Inc.
July 6, 2023
Page 4
You may contact Katharine Garrett at 202-551-2332 or William Schroeder at 202-551-
3294 if you have questions regarding comments on the financial statements and related
matters. Please contact Aisha Adegbuyi at 202-551-8754 or Christian Windsor at 202-551-
3419 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Finance
cc: Steven Lanter