0001410578-16-000844.txt : 20160831 0001410578-16-000844.hdr.sgml : 20160831 20160617204015 ACCESSION NUMBER: 0001410578-16-000844 CONFORMED SUBMISSION TYPE: DRSLTR PUBLIC DOCUMENT COUNT: 1 FILED AS OF DATE: 20160617 FILER: COMPANY DATA: COMPANY CONFORMED NAME: FIRST HAWAIIAN, INC. CENTRAL INDEX KEY: 0000036377 STANDARD INDUSTRIAL CLASSIFICATION: STATE COMMERCIAL BANKS [6022] IRS NUMBER: 990156159 STATE OF INCORPORATION: DE FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: DRSLTR BUSINESS ADDRESS: STREET 1: 999 BISHOP STREET CITY: HONOLULU STATE: HI ZIP: 96813 BUSINESS PHONE: 808-525-7000 MAIL ADDRESS: STREET 1: 999 BISHOP STREET CITY: HONOLULU STATE: HI ZIP: 96813 FORMER COMPANY: FORMER CONFORMED NAME: BANCWEST CORP/HI DATE OF NAME CHANGE: 19981105 FORMER COMPANY: FORMER CONFORMED NAME: FIRST HAWAIIAN INC DATE OF NAME CHANGE: 19920703 DRSLTR 1 filename1.htm

 

 

June 17, 2016

 

Dietrich A. King

 

Division of Corporation Finance,

 

Securities and Exchange Commission,

 

100 F Street, NE,

 

Washington, DC 20549.

 

 

Re:

First Hawaiian, Inc. Confidential Draft Registration Statement on Form S-1 (File No. 377-01277)

 

 

Dear Mr. King:

 

On behalf of our client, First Hawaiian, Inc. (the “Company”), enclosed please find a copy of Confidential Draft Submission No. 4 (the “Revised Draft”) of the above-referenced Registration Statement (the “Registration Statement”), as submitted to the Securities and Exchange Commission (the “Commission”) on a confidential basis on the date hereof, marked to show changes from the draft of the Registration Statement submitted to the Commission confidentially on May 13, 2016.

 

The changes reflected in the Revised Draft include those made in response to the comments of the staff of the Commission (the “Staff”) set forth in the Staff’s letter of May 25, 2016 (the “Comment Letter”). The Revised Draft also includes other changes that are intended to update, clarify and render more complete the information contained therein.

 

For your convenience, we have reproduced each of the Staff’s comments below and provided responses below each comment. Capitalized terms used in this letter and not otherwise defined have the meanings assigned to such terms in the Registration Statement.

 


 

Risk Factors

 

Risks Related to Our Business

 

Concentrated exposures to certain asset classes and individual obligors may unfavorably impact our operations, page 22

 

1.                                      We note your new risk factor. Please revise the risk factor either to identify or to provide representative illustrations of the specific areas of concentration giving rise to the risks the risk factor is intended to address.

 

The Company has revised the disclosure on pages 23 and 24 of the Revised Draft in response to the Staff’s comment.

 

Unaudited Interim Condensed Combined Financial Statements
Notes to Condensed Combined Financial Statements (unaudited)
Note 2. Investment Securities — Visa Class B Restricted Shares, page F-91

 

2.                                      We note your disclosure on page 75 that you attribute your increase in net income in the first quarter of 2016 when compared to the same period in the prior year primarily to the $22.7 million gain on the sale of 274,000 shares of Visa Class B restricted shares. Please enhance your disclosure to include a discussion of when and how you acquired the Visa Class B restricted shares as well as the number of shares owned and their carrying value at each period end (i.e., March 31, 2016, December 31, 2015 and December 31, 2014).

 

The Company has revised the disclosure on page F-92 of the Revised Draft in response to the Staff’s comment.

 

*                                         *                                         *

 

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If you have additional questions or require any additional information with respect to the Registration Statement or this letter, please do not hesitate to contact me at (212) 558-4175 or by email (clarkinc@sullcrom.com).

 

 

Yours truly,

 

 

 

/s/ Catherine M. Clarkin

 

Catherine M. Clarkin

 

(Enclosure)

 

cc:

Benjamin Phippen

 

Amit Pande

 

(Securities and Exchange Commission)

 

 

 

Robert S. Harrison

 

Eric Yeaman

 

(First Hawaiian, Inc.)

 

 

 

Jennifer L. Lee

 

Yael R. Tzipori

 

(Sullivan & Cromwell LLP)

 

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