(LETTERHEAD)
Via U.S. Mail and fax to 202-772-9208
September 28, 2007
Mr. Kevin W. Vaughn
Branch Chief
Mail Stop 4561
Division of Corporation Finance
Securities and Exchange Commission
Washington, D.C. 20549
Re:Sterling Bancorp — File No. 001-05273
Dear Mr. Vaughn:
This is in response to your letter, dated September 19, 2007, regarding staff comments on the Company’s Form 10-K for the fiscal year ended December 31, 2006 and Form 10-Q for the fiscal quarter ended June 30, 2007. For your convenience, we have reproducedin boldface typethe specific comments included in your letter.
Form 10-K
Loan portfolio, page 26
| 1. | | Please revise, here and in similar disclosures elsewhere in your filing, to separately present the balances attributable to your receivable factoring business. |
Response: The Company will include this requested revision in future filings on Form 10-K and Form 10-Q, commencing with our quarterly report on Form 10-Q for the quarter ending September 30, 2007.
Form 10-Q for June 30, 2007
| 2. | | Please revise to include the disclosures required by Item IV.A of Industry Guide 3 for each quarterly period presented. |
Mr. Kevin W. Vaughn
Division of Corporation Finance
Securities and Exchange Commission
September 28, 2007
Page 2
Response: The Company will include this requested revision in future quarterly reports on Form 10-Q, commencing with our report on Form 10-Q for the quarter ending September 30, 2007.
* * * *
In connection with our responses to your comments on the Company’s filing, the Company acknowledges that
| | • | | the Company is responsible for the adequacy and accuracy of the disclosure in the filing; |
| |
| | • | | 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 staff 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 regarding our responses to your comments or have any additional comments, please do not hesitate to call me at 212-757-8035.
| | | | | | | |
| | | | | Very truly yours, |
| | | | | | | |
| | | | | STERLING BANCORP |
| | | | | | | |
| | | | | By | | /s/ John W. Tietjen |
| | | | | | | |
| | | | | | | John W. Tietjen |
| | | | | | | Executive Vice President and Chief Financial Officer |
| cc: | | Mr. Paul V. Jensen, Jr. | | | | |
| | | (KPMG LLP) | | | | |
| | | | | | | |
| | | Daniel Dunson, Esq. | | | | |
| | | (Sullivan & Cromwell LLP) | | | | |
