United States securities and exchange commission logo
January 26, 2024
Dale Gibbons
Chief Financial Officer
Western Alliance Bancorporation
One E. Washington Street, Suite 1400
Phoenix, AZ 85004
Re: Western Alliance
Bancorporation
Form 10-K for the
Fiscal Year Ended December 31, 2022
Form 10-Q for the
Quarterly Period Ended September 30, 2023
Response Dated
October 10, 2023
File No. 001-32550
Dear Dale Gibbons:
We have reviewed your October 10, 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.
Form 10-Q filed October 31, 2023
Concentration of Lending Activities, page 75
1. We note the tabular
disclosure and discussion on page 75 detailing the composition of
your gross loan
portfolio, which includes commercial real estate ( CRE ). Given the
significance of CRE in
your total loan portfolio, please revise your disclosures, in future
filings, to further
discuss other CRE characteristics (e.g., current weighted average and/or
range of loan-to-value
ratios, updated vacancy 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.
Please contact Lory Empie at 202-551-3714 or John Nolan at
202-551-3492 if you have
questions regarding comments on the financial statements and related
matters. Please contact
John Stickel at 202-551-3324 or James Lopez at 202-551-3536 with any
other questions.
Dale Gibbons
Western Alliance Bancorporation
January 26, 2024
Page 2
FirstName LastNameDale Gibbons Sincerely,
Comapany NameWestern Alliance Bancorporation
Division of Corporation Finance
January 26, 2024 Page 2 Office of Finance
FirstName LastName