United States securities and exchange commission logo
January 5, 2024
Michael Carotenuto
Chief Financial Officer
Cambridge Bancorp
1336 Massachusetts Avenue
Boston, MA 02138
Re: Cambridge Bancorp
Form 10-K for the
year ended December 31, 2022
Form 10-Q for the
quarter ended September 30, 2023
Response dated
December 19, 2023
File No. 001-38184
Dear Michael Carotenuto:
We have reviewed your December 19, 2023 response to our comment
letter and have the
following comment.
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. Unless
we note otherwise, any references to prior comments are to comments in
our December 12,
2023 letter.
Response Letter dated December 19, 2023
General
1. We note your draft
disclosure does not address the use of derivative financial instruments,
although page 91 of the
Form 10-K indicates that you use derivatives to manage interest
rate and other economic
risks. Please revise your draft disclosure to further clarify
whether and how
derivative financial instruments are used to manage economic risks,
including whether the
simulation and EVE model outputs reflect such use of derivatives.
Michael Carotenuto
FirstName
CambridgeLastNameMichael Carotenuto
Bancorp
Comapany
January NameCambridge Bancorp
5, 2024
January
Page 2 5, 2024 Page 2
FirstName LastName
Please contact Michael Volley at 202-551-3437 or Amit Pande at
202-551-3423 if you
have questions regarding comments on the financial statements and related
matters. Please
contact Madeleine Joy Mateo at 202-551-3465 or James Lopez at 202-551-3536 with
any other
questions.
Sincerely,
Division of Corporation
Finance
Office of Finance