Attorneys and Counselors at Law |
October 19, 2006
VIA EDGAR AND FAX TO (202) 772-9210
Mr. Benjamin Phippen
Staff Accountant
Division of Corporation Finance
Securities and Exchange Commission
450 Fifth Street, NW
Washington, DC 20549-0404
RE: | BancFirst Corporation; |
Form | 10-K for the fiscal year ended December 31, 2005 |
File Number 0-14384 |
Dear Mr. Phippen:
This letter is in response to your letter dated October 10, 2006 (the “Reply Letter”) to Mr. David E. Rainbolt, President and Chief Executive Officer of BancFirst Corporation (the “Company”), regarding the Company’s August 25, 2006 response to comments of the Staff of the Securities and Exchange Commission (the “Commission”) with respect to the Company’s Annual Report on Form 10-K for the year ended December 31, 2005.
For ease of reference, the Staff comment contained in the Reply Letter is reprinted below in italics, followed by the corresponding response of the Company.
Form 10-K for the Fiscal Year Ended December 31, 2005
1. | We reviewed your response to comment 2 of our letter dated April 19, 2006. We believe the restatement of your previously issued financial statements for the years ended December 31, 2004 and 2003 was a material restatement, for which an Item 4.02 Form 8-K is required to disclose to investors that the previously issued financial statements should not be relied upon. Please file an Item 4.02 Form 8-K announcing non-reliance on these previously issued financial statements. |
Response:On October 19, 2006, the Company filed the requested Item 4.02 Form 8-K with the Commission.
Please direct any questions, comments or advice of the Commission Staff to me atjtimmons@dayedwards.com or by telephone at (405) 239-2121 (fax: (405) 228-1117), or to
2900 Oklahoma Tower 210 Park Avenue Oklahoma City, Oklahoma 73102-5605 Telephone (405) 239-2121 Telecopier (405) 236-1012
www.dayedwards.com
DAY, EDWARDS, PROPESTER & CHRISTENSEN, P.C.
Mr. Benjamin Phippen, Staff Accountant
Division of Corporation Finance
Securities and Exchange Commission
October 19, 2006
Page 2
Randy Foraker, Chief Accounting Officer of the Company, atrforaker@bancfirst.com or by telephone at (405) 270-1044 (fax: (405) 270-1089).
Very truly yours,
/s/ Jeanette C. Timmons
Jeanette C. Timmons
Counsel to BancFirst Corporation
cc: | David E. Rainbolt, President |
BancFirst Corporation |
Joe T. Shockley, Executive Vice President and Chief Financial Officer |
BancFirst Corporation |
Randy Foraker, Executive Vice President, Chief Risk Officer and Chief Accounting Officer |
BancFirst Corporation |