United States securities and exchange commission logo
December 4, 2023
Scott W. Shockey
Chief Financial Officer
Ohio Valley Banc Corp.
420 Third Avenue
Gallipolis, OH 45631
Re: Ohio Valley Banc
Corp.
Form 10-K for the
Annual Fiscal Period Ended December 31, 2022
Form 10-Q for the
Quarterly Period Ended September 30, 2023
File No. 000-20914
Dear Scott W. Shockey:
We have limited our review of your filing to the financial
statements and related
disclosures and have the following comments.
Please respond to this letter 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 a
comment applies to your facts and circumstances, please tell us why in
your response.
After reviewing your
response to this letter, we may have additional comments.
Form 10-K for the Annual Fiscal Period Ended December 31, 2022
Exhibit 13 - OVBC 2022 Annual Report
Management's Discussion and Analysis of Financial Condition and Results
of Operations
Liquidity, page 73
1. We note your disclosure
that management does not rely on any single source of liquidity
and monitors your
liquidity level. We also note that your liquidity section only appears to
describe and quantify
FHLB advances as a liquidity source, and that your risk factors (10-
K page 27) note that
your liquidity contingency funding is highly concentrated in FHLB
funding. In future
filings, please enhance your liquidity disclosures to, as applicable: (i)
note and quantify any
other liquidity sources; (ii) provide comparative discussion of
uninsured deposits
versus available sources of liquidity; and (iii) discuss any policy
guidelines or metrics
related to managing liquidity (e.g., funding or coverage ratios, etc.)
and uninsured deposits
(e.g., internal limits on concentrations in uninsured or brokered
deposits, etc.).
Scott W. Shockey
Ohio Valley Banc Corp.
December 4, 2023
Page 2
Form 10-Q for the Quarterly Period Ended September 30, 2023
Comparison of Financial Condition at September 30, 2023 and December 31, 2022
Loans, page 35
2. Given the significance of commercial real estate ("CRE") in your total
loan portfolio,
please revise your disclosures, in future filings, to further
disaggregate the composition of
your CRE loan portfolio by borrower type (e.g., by office, hotel,
multifamily, etc.),
geographic concentrations and other characteristics (e.g., current
weighted average and/or
range of loan-to-value ratios, occupancy rates, etc.), if any. In
addition, revise to describe
the specific details of any risk management policies, procedures or
other actions
undertaken by management in response to the current environment.
Deposits, page 37
3. We note your disclosures here and in Note 10 regarding increased
brokered deposits as of
September 30, 2023 as compared to December 31, 2022, which primarily
were to fund
asset growth. We also note that your June 30, 2023 Form 10-Q filing
refers to increased
brokered CD issuances to manage your tightened liquidity position
during the first six
months of 2023. Where applicable, please revise your disclosure in
future filings to
provide additional quantitative and qualitative information relating
to your deposits,
liquidity and risk management approach, such as:
stressors causing tightened liquidity and any resulting changes in
your related
management approach;
changes in your deposit base and funding costs that are likely to
result in material
liquidity or funding cost changes;
any impact that deposit changes have on your liquidity and funding
costs;
any related negative impacts to net interest margin; and
potential effects on liquidity and funding for deposits that fail
to roll over.
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.
Please contact Cara Lubit at 202-551-5909 or Lory Empie at 202-551-3714
with any
questions.
FirstName LastNameScott W. Shockey Sincerely,
Comapany NameOhio Valley Banc Corp.
Division of
Corporation Finance
December 4, 2023 Page 2 Office of
Finance
FirstName LastName