Unassociated Document
[GLEN
BURNIE BANCORP LETTERHEAD]
November
19, 2009
Via EDGAR and
FEDEX
Mr. Hugh
West
Accounting
Branch Chief
Division
of Corporation Finance
Securities
and Exchange Commission
100 F
Street, NE
Washington,
DC 20549
RE:
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Glen
Burnie Bancorp (the “Company”)
Form
10-K for the Fiscal Year ended December 31, 2008
Form
10-Q for the Quarter ended September 30, 2009
File
No. 000-24047
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Dear Mr.
West:
I am
writing to you in response to your letter of November 4, 2009 regarding the
referenced file number. Below are the Company’s responses to the
comments raised.
Form
10-K for the Fiscal Year Ended December 31, 2008
Independent Accountants
Report, page F-1
1. While
the Report of the Company’s Independent Registered Public Accounting Firm on the
Company’s audited financial statements for the fiscal year ended December 31,
2009 was manually executed, the signature was mistakenly omitted from the report
included in the December 31, 2008 Form 10-K. The Company has filed,
via EDGAR, an amended Form 10-K which includes the signature.
Form
10-Q for the Quarterly Period Ended September 30, 2009
Notes to Consolidated
Financial Statements – Note 5 – Fair Value, page 9
2. We
note your comment and will revise future filings to provide the disclosures
required by ASC 320-10-50. We supplementally advise the staff that
the gross unrealized losses and fair value, aggregated by investment category
and length of time that individual securities have been in a continuous
unrealized loss position, at September 30, 2009 are as follows:
Mr. Hugh
West
Division
of Corporation Finance
Securities
and Exchange Commission
November
19, 2009
Page
2
SEPTEMBER
30,2009
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UNREALIZED
LOSS POSITION
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LESS
THAN 12 MONTHS
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LESS
THAN 12 MONTHS
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TOTAL
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FAIR
VALUE
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UNREALIZED
LOSS
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FAIR
VALUE
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UNREALIZED
LOSS
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FAIR
VALUE
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UNREALIZED
LOSS
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STATE
AND MUNICIPAL
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370,732.50 |
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1,030.49 |
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4,502,697.10 |
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284,913.25 |
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4,873,429.60 |
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285,943.74 |
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CORPORATE
TRUST PREFERRED
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0.00 |
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0.00 |
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35,374.74 |
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1,139,200.39 |
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35,374.74 |
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1,139,200.39 |
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MORTGAGE
BACKED
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6,427,236.83 |
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44,949.81 |
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0.00 |
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0.00 |
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6,427,236.83 |
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44,949.81 |
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6,797,969.33 |
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45,980.30 |
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4,538,071.84 |
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1,424,113.64 |
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11,336,041.17 |
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1,470,093.94 |
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In the
first quarter of 2009, the Bank wrote down $30,000 on the value of a Trust
Preferred security held by the Bank due to a default by one of the financial
institutions in the Trust Preferred pool. This other-than-temporary
impairment was reflected as a charge to income in the first quarter of
2009. The write down represented 2.4% of the initial investment in
these securities.
Declines
in the fair value of held to maturity and available for sale securities below
their cost that are deemed to be other than temporary are reflected in earnings
as realized losses. In estimating other-than-temporary impairment
losses, management considers, among other things, (i) the length of time and the
extent to which the fair value has been less than cost, (ii) the financial
condition and near-term prospects of the issuer, and (iii) the intent and
ability of the Company to retain it’s investment in the issuer for a period of
time sufficient to allow for any anticipated recovery in fair
value.
On
September 30, 2009 the Bank held 13 investment securities having continuous
unrealized loss positions of more than 12 months. Management has
determined that all unrealized losses are either due to increases in market
interest rates over the yields available at the time the underlying securities
were purchased, current call features that are nearing, and the effect the
sub-prime market has had on all mortgage-backed securities. The Bank
has no mortgage-backed securities collateralized by sub-prime
mortgages. The fair value is expected to recover as the bonds
approach their maturity date or repricing date or if market yields for such
investments decline. Management does not believe that any of the
securities are impaired due to reasons of credit quality. Management
also does not have the desire to sell these securities in the near
term. Accordingly, as of September 30, 2009, management believes the
impairments detailed in the table above are temporary and no impairment loss has
been realized in the Company’s consolidated income statement.
Mr. Hugh
West
Division
of Corporation Finance
Securities
and Exchange Commission
November
19, 2009
Page
3
General
The
Company hereby acknowledges that the Company is responsible for the adequacy and
accuracy of the disclosure in the filing, and staff comments or changes to
disclosure in response to staff comments do not foreclose the Commission from
taking any action with respect to the filing. The Company further
acknowledges that the Company may not assert staff comments as a defense in any
proceeding initiated by the Commission or any person under the federal
securities laws of the United States.
Should
you require any further information or have additional comments, please contact
me.
Sincerely,
GLEN
BURNIE BANCORP
/s/ John
E. Porter
John E.
Porter
Chief
Financial Officer
cc:
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Mr.
Michael G. Livingston
Chief
Executive Officer
Marc
Thomas, Staff Accountant
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