TEXT-EXTRACT 2 filename2.txt United States securities and exchange commission logo November 16, 2023 Dean Y. Shigemura Chief Financial Officer Bank of Hawaii Corporation 130 Merchant Street Honolulu, HI 96813 Re: Bank of Hawaii Corporation Form 10-K for Fiscal Year Ended December 31, 2022 Form 10-Q for Fiscal Quarter Ended June 30, 2023 Form 10-Q for Fiscal Quarter Ended September 30, 2023 Response dated October 26, 2023 File No. 001-06887 Dear Dean Y. Shigemura: We have reviewed your filing and have the following comments. 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. Quarterly Report on Form 10-Q for Fiscal Quarter Ended September 30, 2023 Management's Discussion and Analysis of Financial Condition and Results of Operations Interest Rate Risk, page 62 1. We note the response to our prior comment 3 and the disclosure on pages 62 and 63 in the Form 10-Q for the Quarterly Period Ended September 30, 2023. We note your net interest income sensitivity disclosures in Table 17 only disclose the impacts within a -200 basis points to a +200 basis points range; however, your disclosure on page 62 and response addresses a -400 basis points to a +400 basis points range used by management. Please confirm that you will revise your future filings to include a sensitivity analysis ranging from -400 basis points to +400 basis points. 2. We note your disclosure on page 62 that you also measure your interest rate exposure using economic value of equity ("EVE") sensitivity. Please confirm that you will revise your future filings to include qualitative discussion of how EVE is utilized to manage your Dean Y. Shigemura Bank of Hawaii Corporation November 16, 2023 Page 2 interest rate risk exposure. To the extent it is used by management, disclose quantitative EVE sensitivity information in your future filings. We remind you that the company and its management are responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the staff. Please contact Michael Henderson at 202-551-3364 or Marc Thomas at 202-551-3452 if you have questions regarding comments on the financial statements and related matters. Please contact Tonya Aldave at 202-551-3601 or Todd Schiffman at 202-551-3491 with any other questions. Sincerely, FirstName LastNameDean Y. Shigemura Division of Corporation Finance Comapany NameBank of Hawaii Corporation Office of Finance November 16, 2023 Page 2 cc: Patrick M. McGuirk, Esq. FirstName LastName