0001104659-14-052219.txt : 20141001 0001104659-14-052219.hdr.sgml : 20141001 20140718145311 ACCESSION NUMBER: 0001104659-14-052219 CONFORMED SUBMISSION TYPE: CORRESP PUBLIC DOCUMENT COUNT: 1 FILED AS OF DATE: 20140718 FILER: COMPANY DATA: COMPANY CONFORMED NAME: CITY NATIONAL CORP CENTRAL INDEX KEY: 0000201461 STANDARD INDUSTRIAL CLASSIFICATION: NATIONAL COMMERCIAL BANKS [6021] IRS NUMBER: 952568550 STATE OF INCORPORATION: DE FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 400 N ROXBURY DR CITY: BEVERLY HILLS STATE: CA ZIP: 90210 BUSINESS PHONE: 3108886000 MAIL ADDRESS: STREET 1: 400 N ROXBURY DR CITY: BEVERLY HILLS STATE: CA ZIP: 90210 CORRESP 1 filename1.htm

 

July 18, 2014

 

VIA EDGAR

 

Mr. John Nolan

Senior Assistant Chief Accountant

U.S. Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549

 

Re:                        City National Corporation

Form 10-K for the period ended December 31, 2013

Filed March 3, 2014

Response dated June 30, 2014

File No. 001-10521

 

Dear Mr. Nolan:

 

On behalf of City National Corporation (the “Company”), this letter is in response to the comment letter dated July 3, 2014, from you to Mr. Carey with respect to the Company’s Annual Report on Form 10-K for the period ended December 31, 2013. The text of your letter has been included for your reference and the Company’s response is presented below the comment.

 

City National Corporation Form 10-K

 

Management’s Discussion and Analysis

 

1.          We note your response to prior comment 1b included in your letter dated June 30, 2014.  In your example included in Exhibit A, you state that the discount period for the FDIC indemnification asset is two years and is based on the estimated timing of the collection of loss from the FDIC.  We note the remaining expected life of the related loans was five years.

 

a.          It appears that you are not using the contractual term of the FDIC indemnification asset for your discount period.  Please tell us how you considered the guidance in ASU 2012-06 and ASC 805-20-35-4B which states that any amortization of changes in value of an indemnification asset is limited to the lesser of the contractual term of the indemnification agreement and the remaining life of the indemnified assets.

 

In accordance with ASU 2012-06 and ASC 805-20-35-4B, the Company amortizes the FDIC indemnification asset over a period that is limited to the lesser of the contractual term of the FDIC loss-sharing agreements and the remaining life of the indemnified assets (the “amortization period”), which in our case is the contractual term of the FDIC loss-sharing agreements. The Company embeds the contractual term of the FDIC loss-sharing agreements into the cash flow model, which amortizes the FDIC indemnification asset using a level yield method (also referred to as the effective yield method).

 

b.          Please tell us the impact on your financial statements if you used the lesser of the contractual term of the indemnification asset or remaining life of the asset as your discount period for 2013 and 2014.

 


 

Mr. John Nolan

U.S. Securities and Exchange Commission

July 18, 2014

Page Two

 

As discussed in our response to comment 1a above, the Company does use the lesser of the contractual term of the FDIC loss-sharing agreements and the remaining life of the indemnified assets as its discount period. The Company’s financial statements for 2013 and 2014 properly reflect this application of ASU 2012-06 and ASC 805-20-35-4B.

 

If you have any questions or comments concerning the responses contained in this letter, please do not hesitate to contact the undersigned at (310) 888-6777.

 

Sincerely,

 

 

 

/s/ Christopher J. Carey

 

 

 

Christopher J. Carey

 

Executive Vice President

 

Chief Financial Officer

 

 

 

cc:

Russell Goldsmith

 

 

President and Chief Executive Officer

 

 

 

 

 

Michael B. Cahill

 

 

Executive Vice President

 

 

General Counsel & Secretary

 

 

 

 

 

Olga Tsokova

 

 

Senior Vice President

 

 

Chief Accounting Officer