December 3, 2009
Mr. Justin Dobbie
Attorney Advisor
Securities and Exchange Commission
Division of Corporation Finance
Washington, D.C. 20549
| | | | |
| | Re: | | Green Bankshares, Inc |
| | | | Form 10-K for fiscal year ended December 31, 2008 |
| | | | Form 10-Q for the period ended June 30, 2009 |
| | | | File Number 001-14289 |
Dear Mr. Dobbie,
In response to your letter dated November 25, 2009, requesting additional information concerning the above referenced items, Green Bankshares, Inc. (the “Company”) provides the information detailed below:
Form 10-K for the fiscal year ended December 31, 2008
SEC Question/observation:
Item 11. Executive Compensation, page 87
Compensation Discussion and Analysis, page 18 of Definitive Proxy Statement on Schedule 14A
| 1. | | We note your response to comment 2 in our letter dated October 16, 2009. Please confirm that you will file a written description of your Cash Incentive Plan with your next periodic report. Refer to Item 601(b)(10)(iii)(A) of Regulation S-K. |
Company Response:
The Company will file a written description of its Cash Incentive Plan in its next periodic report.
The Company hereby acknowledges that:
| • | | The Company is responsible for the adequacy and accuracy of the disclosure in the filing; |
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| • | | The staff comments or changes to disclosure in response to staff comments do not foreclose the Commission from taking any action with respect to the filing; and |
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| • | | The Company may not assert comments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States. |
If you have any questions concerning our responses to your questions and comments, please do not hesitate to contact James E. Adams, the Company’s Chief Financial Officer at (423) 278-3050 or by FAX at (423) 278-3090.
Sincerely,
/s/ Stan Puckett
Stan Puckett
Chairman and Chief Executive Officer