Alston&Bird llp
The Atlantic Building
950 F Street, NW
Washington, DC 20004-1404
202-239-3300
Fax: 202-654-4952
www.alston.com
Dennis O. Garris | Direct Dial: 202-239-3452 | Email: dennis.garris@alston.com |
January 29, 2013
U.S. Securities and Exchange Commission Division of Corporation Finance 100 F Street, N.E. Washington, DC 20549
Attn: Michael R. Clampitt, Senior Counsel
Re: Suffolk Bancorp Registration Statement on Form S-1 Filed January 4, 2013 File No. 333-184530 |
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Dear Mr. Clampitt:
As you know, I represent Wellington Management Company, LLP (“Wellington Management”) with respect to the above referenced selling shareholder Form S-1 (the “Form S-1”) filed by Suffolk Bancorp (the “Issuer”) and the comments by the Staff that Wellington Management should identify a natural person at Wellington Management in the selling shareholder table.
In a telephone conversation on January 24, 2013, Michele Anderson, Chief of the Office of Mergers and Acquisitions and Jonathan Ingram, Deputy Chief Counsel, requested that we provide additional information in response to the Staff’s comments. Specifically, the staff had a question about the following sentence in Wellington Management’s previous letter: “Instead, Wellington Management determines which individual or individuals will serve in such capacity, and is free to modify such arrangements at any time.” We wish to clarify that there is not a specific individual that Wellington Management chooses to make all the voting and investment decisions for each client account. As previously mentioned, Wellington Management’s investment management agreements with its clients ordinarily do not name a specific individual or individuals to manage an account and the agreements in this specific situation do not. Therefore, beneficial ownership should not be attributed to any single individual within Wellington Management.
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