One North Shore, 12 Federal Street, Suite 503, Pittsburgh, PA 15212
June 30, 2017
VIA EDGAR
Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549
Attention: Yolanda R. Trotter
Staff Accountant
| Re: | F.N.B. Corporation |
Form10-K for Fiscal Year Ended December 31, 2016
Filed February 23, 2017
Form10-Q for the Quarterly Period Ended March 31, 2017
Filed May 8, 2017
FileNo. 001-31940
Dear Ms. Trotter:
The purpose of this letter is to provide a detailed response to the comment contained in the Commission’s June 20, 2017 letter to F.N.B. Corporation. For convenience of reference, we have included in italics the Staff’s comment followed by our response to the comment below.
Form10-Q for the Quarterly Period Ended March 31, 2017
| Item 7. | Management’s Discussion and Results of Operations |
Non-GAAP Financial Measures and Key Performance Indicators
Table 26 – Net Interest Margin, excluding purchase accounting impact, page 76
| 1. | We note your disclosure of thenon-GAAP measure, net interest margin, which excludes purchase accounting impact (FTE). The exclusion of this adjustment from yournon-GAAP metric is not appropriate as it appears to represent a tailored accounting principle because it only excludes the effects of acquisition accounting, rather than adjustments that may try to reflect true organic growth. Therefore, in future filings, to the extent material, please confirm you will no longer present this type ofnon-GAAP adjustment. |
As requested, in future filings we will not present the adjustednon-GAAP measure of net interest margin, excluding purchase accounting impact (FTE). Instead, as previously discussed with the Staff, in future filings we will disclose the dollar amount and basis point impact of purchase accounting on the reportednon-GAAP measures of net interest income (FTE) and net interest margin (FTE), respectively.
We believe that the foregoing response adequately addresses your comment. Please contact me at (724)983-3745 if you have any questions or would like further information about this response.
| Sincerely, |
| /s/ Vincent J. Calabrese, Jr. |
| Vincent J. Calabrese, Jr. |
| Chief Financial Officer |
| F.N.B. Corporation |
| cc: | Chris Harley |