9650 FLAIR DRIVE - Mail Code EL-8-H EL MONTE, CALIFORNIA 91731 (626) 279-3652 • FAX (626) 279-3285 |
June 30, 2010
Mr. Christian Windsor, Special Counsel
Mr. Mark Thomas, Senior Staff Accountant
U.S. Securities and Exchange Commission
Division of Corporation Finance
100 F Street, N.E., Mail Stop 4720
Washington, D.C. 20549
Re: | Cathay General Bancorp |
Form 10-K for December 31, 2009 |
File Number 0-18630 |
Dear Mr. Windsor and Mr. Thomas:
On behalf of Cathay General Bancorp (the “Company”), this letter is in response to the comment letter dated June 3, 2010, to Mr. Chen from Mr. Windsor of the staff of the Securities and Exchange Commission (the “Commission”). The references to the comment letter have been shown in bold face for convenience, and the Company’s responses are set forth below the reference.
Comment
In your 1O-Q for the quarter ended March 31, 2010, you disclose that under your agreements with your regulators you have increased capital requirements. Please advise the staff what your required capital levels are, your actual capital amounts and any excess or deficiency over the agreed capital requirements. Also, revise future filings to provide this disclosure.
The target, actual, and any excess or deficiency capital levels of the Three-Year Capital and Strategic Plan submitted to the FRB SF on January 22, 2010, are as follows:
Tier 1 risk-based capital ratio |
Total risk-based capital ratio |
Tier 1 leverage capital ratio |
Tangible common risk- based ratio |
|||||||||
Actual at 3/31/10 |
14.43 | % | 16.32 | % | 10.07 | % | 9.81 | % | ||||
Target Levels |
11.50 | % | 13.50 | % | 9.50 | % | 5.00 | % | ||||
Excess or (Deficiency) |
2.93 | % | 2.82 | % | .57 | % | 4.81 | % |
The target, actual, and any excess or deficiency capital levels of the Three-Year Capital Plan submitted to the DFI and FDIC on April 30, 2010, are as follows:
Tier 1 risk-based capital ratio |
Total risk-based capital ratio |
Tier 1 to total
assets ratio (beginning 6/30/10) |
|||||||
Actual at 3/31/10 |
13.79 | % | 15.68 | % | Not Yet Applicable | ||||
Target Levels |
11.50 | % | 13.50 | % | 9.50 | % | |||
Excess or (Deficiency) |
2.29 | % | 2.18 | % | Not Yet Applicable |
We will revise future filings to provide this disclosure.
In connection with the foregoing response, the Company acknowledges that:
• | the Company is responsible for the adequacy and accuracy of the disclosure in the filing; |
• | 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; and |
• | 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. |
If you have any questions or comments concerning the Company’s responses, please contact me at (626) 279-3652.
Very truly yours, |
/s/ Heng W. Chen |
Heng W. Chen |
Executive Vice President and Chief Financial Officer |