United States securities and exchange commission logo
December 21, 2023
Paul Frenkiel
Chief Financial Officer
The Bancorp, Inc.
409 Silverside Road
Wilmington, DE 19809
Re: The Bancorp, Inc.
Form 10-K for
Fiscal Year Ended December 31, 2022
File No. 000-51018
Dear Paul Frenkiel:
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 Fiscal Year Ended December 31, 2022
Item 1A. Risk Factors
We derive a significant percentage of our deposits, total assets and . .
.., page 38
1. We note your disclosure
that your top ten relationships accounted for $4.44 billion of
deposits. Please
enhance future filings, in this section or elsewhere as appropriate,
to provide additional
detail such as how such an amount is distributed within the top ten
group for the periods
presented (e.g., 15% for the top client, etc.), whether the clients in
this group have changed
from the prior period, and the extent of additional concentrations
(e.g., geography,
industry, or other relevant characteristics, as applicable).
Item 7. Management's Discussion and Analysis of Financial Condition and
Results of Operations
Liquidity and Capital Resources, page 58
2. We note your disclosure
that the Federal Deposit Insurance Corporation issued a new
regulation in December
2020 which resulted in the majority of your deposits being
reclassified from
brokered to non-brokered. In future filings, please quantify the amount
of brokered deposits
for each of the periods presented or state that they are immaterial. In
Paul Frenkiel
FirstName LastNamePaul Frenkiel
The Bancorp, Inc.
Comapany21,
December NameThe
2023 Bancorp, Inc.
December
Page 2 21, 2023 Page 2
FirstName LastName
addition, to the extent that you experience material changes in your
deposit mix or
customers / customer base, provide additional quantitative and
qualitative information in
future filings, here or in a deposit disclosure section, explaining
such changes and the
related impact on your funding costs and liquidity, if any.
Deposits, page 79
3. We note your disclosure that your average rate paid on demand and
interest checking
accounts reflects fees paid to affinity groups based upon a rate
index. We also note your
disclosure on page 4 that certain fees increase as market interest
rates increase, while other
fee rates may be fixed. Please enhance disclosure in future filings to
provide additional
information regarding fees paid to affinity groups. This should
include, but not be limited
to:
details regarding how such fees are determined, including any
specific differences in
how fixed and variable rates are determined and paid;
the proportion of deposits with fixed versus variable rates;
whether you use the same rate index for each affinity group;
the extent to which rates could change and have changed based on
volumes, product
mix, or client mix; and
quantification of how much of period-over-period average changes
related to
different factors (e.g., product mix, market rate changes, etc.).
4. We note your disclosures regarding deposits. In future filings, please
revise to address the
items below.
Define and explain your short-term deposits, including additional
context regarding
how and from whom they are sourced.
Clearly identify which items in your deposit table on page 79 are
interest-bearing and
non-interest-bearing amounts, and disaggregate demand deposit
amounts related to
affinity group fees from those related to interest-bearing
checking accounts.
Quantify and discuss your demand deposit composition and how it
has changed over
the periods presented, such as significant categories within your
mix of prepaid card
account types (e.g., salary, medical spending, etc.), any changes
in this mix over time,
and any notable trends specific to individual categories within
this mix. In addition,
to the extent that it applies, link changes in your deposit base
to any resulting material
changes in funding costs.
Enhance your discussion, here or in another appropriate location,
of the composition
of your affinity relationships, such as industry, geographic,
size, or other relevant
characteristics, as well as whether and how that composition has
changed over the
periods presented.
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.
Paul Frenkiel
The Bancorp, Inc.
December 21, 2023
Page 3
Please contact Jee Yeon Ahn at 202-551-3673 or Cara Lubit at
202-551-5909 with any
questions.
FirstName LastNamePaul Frenkiel Sincerely,
Comapany NameThe Bancorp, Inc.
Division of Corporation
Finance
December 21, 2023 Page 3 Office of Finance
FirstName LastName