United States securities and exchange commission logo
May 24, 2022
Rodger McHargue
Chief Financial Officer
First Financial Corp /IN/
One First Financial Plaza
Terre Haute, IN 47807
Re: First Financial
Corp /IN/
Form 10-K for the
Fiscal Year Ended December 31, 2021
Filed March 9, 2022
Form 10-Q for the
Quarterly Period Ended March 31, 2022
Filed May 4, 2022
File No. 000-16759
Dear Mr. McHargue:
We have limited our review of your filing to the financial
statements and related
disclosures and have the following comments. In some of our comments, we
may ask you to
provide us with information so we may better understand your disclosure.
Please respond to these comments within ten business days by
providing the requested
information or advise us as soon as possible when you will respond. If
you do not believe our
comments apply to your facts and circumstances, please tell us why in
your response.
After reviewing your
response to these comments, we may have additional comments.
Form 10-K for the Fiscal Year Ended December 31, 2021
Item 7. Management's Discussion and Analysis of Financial Condition and
Results of Operations
Critical Accounting Policies and Estimates, page 32
1. We note that the
allowance for credit losses is estimated based on management's
assessment of several
factors, including: reviews and evaluations of specific loans,
changes in the nature
and volume of the loan portfolio, current economic conditions,
nonperforming loans,
determination of acquired loans as purchase credit deteriorated, and
reasonable and
supportable forecasts. Please provide us proposed revised disclosure to be
included within future
filings that address the following items:
Identifies key
quantitative inputs in your estimate of the allowance for credit losses;
Explains and
quantifies how these key quantitative inputs have changed from period
to period;
Rodger McHargue
FirstName LastNameRodger McHargue
First Financial Corp /IN/
Comapany
May NameFirst Financial Corp /IN/
24, 2022
May 24,
Page 2 2022 Page 2
FirstName LastName
Quantifies the qualitative component(s) of your estimate and
explains or shows how
it interacts with the quantitative component during the period
presented; and
Details the length of time in your reasonable and supportable
forecasts and the
reversion method you applied after the reasonable and supportable
forecast period, if
applicable.
Refer to Item 303(b)(3) of Regulation S-K and ASC 326-20-50-11.
Comparison and Discussion of 2021 Balance Sheet to 2020
Allowance for Credit Losses, page 38
2. We note your presentation of the allowance for credit losses activity
at the loan portfolio
level and your related discussion of changes in the provision for
credit losses on page 35.
We also note that you present aging and risk rating information by
class of loans on pages
73-78. In future filings, please expand your discussion to identify
and quantify any
changes or known trends in the activities (i.e., provision,
charge-offs, recoveries)
impacting the allowance for credit losses by class of loan, where
significant. Refer to
Item 303(b)(2) of Regulation S-K.
Item 8. Financial Statements and Supplementary Data
Notes to the Consolidated Financial Statements
Note 7. Allowance for Credit Losses, page 69
3. Please revise your future filings to disclose the amount of
line-of-credit arrangements that
are converted to term loans in each reporting period. Refer to ASC
326-20-50-6A.
Form 10-Q for the period ended March 31, 2022
Management's Discussion and Analysis of Financial Condition and Results of
Operations and
Quantitative and Qualitative Disclosures, page 32
4. We note you attribute the negative provision of $6.6 million for the
quarterly period ended
March 31, 2022 due to the annual model recalibration, the removal of
two qualitative
factors that are no longer applicable and lower loss rates. Please
revise your disclosures, in
future filings, to address the following:
Describe the annual model recalibration process, including more
specific details
regarding the updating of delay periods and qualitative
factor scorecard ranges
and how these incremental changes impacted overall trends in the
model and
provisioning process.
Identify and describe the two qualitative factors and explain why
they were
determined to no longer be applicable.
Quantify and discuss changes the loss rates between the periods
being compared,
including if those changes are concentrated in any specific class
of loans.
Quantify the impact on the provision associated with each of the
attributed factors
identified above.
Rodger McHargue
First Financial Corp /IN/
May 24, 2022
Page 3
5. We note the increase in non-interest income from 2021 to 2022 was
primarily driven by a
$4.0 million legal settlement received in the first quarter. Please
revise your disclosures,
in future filings, to more fully describe the nature and substance of
the legal claims made,
timing of progress and settlement terms.
In closing, we remind you that the company and its management are
responsible for the
accuracy and adequacy of their disclosures, notwithstanding any review,
comments, action or
absence of action by the staff.
You may contact Michael Henderson, Staff Accountant, at 202-551-3364 or
Lory Empie,
Staff Accountant, at 202-551-3714 with any questions.
FirstName LastNameRodger McHargue Sincerely,
Comapany NameFirst Financial Corp /IN/
Division of
Corporation Finance
May 24, 2022 Page 3 Office of
Finance
FirstName LastName