-----BEGIN PRIVACY-ENHANCED MESSAGE----- Proc-Type: 2001,MIC-CLEAR Originator-Name: webmaster@www.sec.gov Originator-Key-Asymmetric: MFgwCgYEVQgBAQICAf8DSgAwRwJAW2sNKK9AVtBzYZmr6aGjlWyK3XmZv3dTINen TWSM7vrzLADbmYQaionwg5sDW3P6oaM5D3tdezXMm7z1T+B+twIDAQAB MIC-Info: RSA-MD5,RSA, NHlwSM7d9fzT2LlV1p4W8EsFriMaBipzI86J0Vhco0MErWTF+NtruGKiyatX+4at OfeR/TO0rngYM3do9SZexQ== 0000000000-05-056231.txt : 20101129 0000000000-05-056231.hdr.sgml : 20101129 20051104134213 ACCESSION NUMBER: 0000000000-05-056231 CONFORMED SUBMISSION TYPE: UPLOAD PUBLIC DOCUMENT COUNT: 1 FILED AS OF DATE: 20051104 FILED FOR: COMPANY DATA: COMPANY CONFORMED NAME: FIRSTCITY FINANCIAL CORP CENTRAL INDEX KEY: 0000828678 STANDARD INDUSTRIAL CLASSIFICATION: SHORT-TERM BUSINESS CREDIT INSTITUTIONS [6153] IRS NUMBER: 760243729 STATE OF INCORPORATION: DE FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: UPLOAD BUSINESS ADDRESS: STREET 1: 6400 IMPERIAL DRIVE CITY: WACO STATE: TX ZIP: 76712 BUSINESS PHONE: 2547511750 MAIL ADDRESS: STREET 1: 6400 IMPERIAL DRIVE CITY: WACO STATE: TX ZIP: 76712 FORMER COMPANY: FORMER CONFORMED NAME: FIRST CITY BANCORPORATION OF TEXAS INC/ DATE OF NAME CHANGE: 19920703 FORMER COMPANY: FORMER CONFORMED NAME: FIRST CITY ACQUISITION CORP DATE OF NAME CHANGE: 19880523 LETTER 1 filename1.txt Mail Stop 3561 November 4, 2005 Via U.S. Mail and Fax (254-761-2957) Mr. Bryan Baker Senior Vice President and Chief Financial Officer FirstCity Financial Corporation 6400 Imperial Drive Waco, Texas 76712 Re: FirstCity Financial Corporation Form 10-K for the year ended December 31, 2004 Filed March 21, 2005 Form 10-Q for the quarter ended June 30, 2005 Filed on August 12, 2005 File No.: 033-19694 Dear Mr. Baker: We have reviewed your response letter dated October 13, 2005 and have the following additional comments. In our comments, we ask you to provide us with supplemental information so we may better understand your disclosure. After reviewing this information, we may or may not raise additional comments. Please understand that the purpose of our review process is to assist you in your compliance with the applicable disclosure requirements and to enhance the overall disclosure in your filing. We look forward to working with you in these respects. We welcome any questions you may have about our comments or on any other aspect of our review. Feel free to call us at the telephone numbers listed at the end of this letter. 1. Refer to your response to comment 1. We continue to believe that you should revise your statement of operations to present "equity in earnings of investments" in accordance with Rule 5-03 of Regulation S-X. 2. Refer to your response to comment 3 and your supporting calculation. Your calculation of average income does not appear correct. Tell us how you calculated the average income amount for each of the three years ended December 31, 2004. 3. It is not appropriate to use the higher of the actual or average income to determine significance. For your guidance if income of the registrant and its subsidiaries consolidated for the most recent fiscal year is at least 10 percent lower than the average of the income for the last five fiscal years, such average income should be substituted for purposes of the computation. Any loss years should be omitted for purposes of computing average income. Further when calculating the average income for years when the operations have been discontinued you need to use the restated financial information in the denominator. Revise or advise. 4. Tell us the name of each partnership included within the Mexican Acquisition Partnerships, the equity in income (loss) associated with each one of them in each of the three years ended December 31, 2004 and the relationship among them. Provide similar information for the European partnerships. * * * * Please respond to these comments within 10 business days or tell us when you will provide us with a response. Please furnish a cover letter with your proposed revisions that keys your responses to our comments and provides any requested supplemental information. Detailed cover letters greatly facilitate our review. Please file your cover letter on EDGAR. Please understand that we may have additional comments after reviewing your responses to our comments. You may contact Andrew Mew, Senior Staff Accountant, at (202) 551-3377 or Ivette Leon, Assistant Chief Accountant, at (202) 551- 3351 if you have questions regarding comments on the financial statements and related matters. Please contact me at (202) 551- 3810 with any other questions. Sincerely, Larry Spirgel Assistant Director ?? ?? ?? ?? FirstCity Financial Corporation November 4, 2005 Page 1 -----END PRIVACY-ENHANCED MESSAGE-----