Suite 900 607 14th St., NW
Washington DC 20005-2018
t 202 508 5800 f 202 508 5858
www.KilpatrickStockton.com
direct dial 202 508 5825
direct fax 202 204 5600
AKaslow@KilpatrickStockton.com
May 11, 2010
Chris Harley
Division of Corporate Finance
U.S. Securities and Exchange Commission
100 F Street, NE
Washington, DC 20549
| Re: | FedFirst Financial Corporation Registration Statement on Form S-1 Filed March 12, 2010 File No. 333-165437 |
Dear Ms. Harley:
On behalf of FedFirst Financial Corporation (the “Company”), we are providing additional information to supplement the response to the staff’s comment letter issued on May 5, 2010.
As discussed in prior correspondence, the Company receives reports from FTN Financial Securities regarding the pooled trust preferred securities that it holds. For each security, the Company receives a report that describes the issuers in the pool and provides summary financial and operating information with respect to each issuer. A copy of the report for one of the securities is enclosed with this letter. The report provides financial condition data (the amount of surplus and assets and asset quality information), operating ratios (net premium written to surplus, net leverage, return on surplus, and combined ratios over different periods) and A.M. Best ratings for each issuer in the pool. The Company evaluates the collateral specific information in this report to assess the credit characteristics of the underlying collateral for each security. The Company believes that it has adequately summarized its review of collateral specific information on page F-19 of the prospectus and that further disclosure would not be useful to an investor.
As previously discussed, the Company uses cash flow modeling provided by FTN Financial Securities. The model provides nine scenarios available within three deal cash flow assumption categories (prepays constant, no prepays, prepays constant utilizing select years and defaults over 5 years and constant thereafter). A copy of the portion of the report that describes the various scenarios and output for one of the model’s scenarios is enclosed with this letter. The Company does not rely on a single scenario for its analysis. Rather, as previously discussed, the
Chris Harley
U.S. Securities and Exchange Commission
May 11, 2010
Page 2
Company reviews the cash flow analysis for each of the scenarios contained within the model. As of December 31, 2009, the securities passed all scenarios with positive cash flow, which indicated that there was no OTTI.
If you have any questions or further comments, please contact the undersigned at (202) 508-5825.
| Very truly yours, |
| /s/ Aaron M. Kaslow |
| KILPATRICK STOCKTON LLP |
Enclosures
| cc: | Paul M. Aguggia, Esq., Kilpatrick Stockton LLP Patrick G. O’Brien, FedFirst Financial Corporation Hugh T. Wilkinson, Esq., Elias, Matz, Tiernan & Herrick L.L.P. |
