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United States securities and exchange commission logo
June 28, 2024
Steven B. Crockett
Chief Financial Officer
South Plains Financial, Inc.
5219 City Bank Parkway
Lubbock, TX 79407
Re: South Plains
Financial, Inc.
Form 10-K for
Fiscal Year Ended December 31, 2023
File No. 001-38895
Dear Steven B. Crockett:
We have limited our review of your filing to the financial
statements and related
disclosures 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.
Form 10-K for Fiscal Year Ended December 31, 2023
Item 7. Management's Discussion and Analysis of Financial Condition and
Results of Operations
Loan Portfolio, page 48
1. We note the tabular
disclosure on page 48 detailing the composition of your loans held for
investment portfolio,
which includes commercial real estate ( CRE ) with approximately
35.9% of your total
loan portfolio as of December 31, 2023. However, you disclose under
Risk Factors on page 26
that your non-owner occupied CRE loans totaled approximately
40.1% of your total
loan portfolio as of December 31, 2023. In addition, we note that the
total amount of your
CRE portfolio in your earnings presentation (e.g., slide 16 of Exhibit
99.2 from the January
26, 2024 Form 8-K) does not agree to the amount presented on
page 48. Please tell us
and revise future filings to address the following:
Reconcile these
disclosures or explain why there appears to be discrepancies in these
disclosures about
your CRE portfolio;
Clearly quantify
and discuss your CRE composition, as well as whether and how that
composition has
changed over the periods presented; and
Steven B. Crockett
South Plains Financial, Inc.
June 28, 2024
Page 2
Disaggregate your CRE loans into owner occupied and non-owner
occupied.
2. Additionally, given the significance of CRE loans in your total loan
portfolio, please
revise future filings to further disaggregate the composition of these
loans to disclose and
quantify by key borrower type (e.g., multifamily, warehouse, office,
retail, etc.),
geographic concentrations in your Texas and New Mexico markets, as
well as current
weighted average and/or range of loan-to-value ratios, and other
characteristics (e.g.,
occupancy rates, etc.) material to an investor s understanding of
these loans. See Item 303
of Regulation S-K.
In closing, 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 Jee Yeon Ahn at 202-551-3673 or John Nolan at
202-551-3492 with any
questions.
FirstName LastNameSteven B. Crockett Sincerely,
Comapany NameSouth Plains Financial, Inc.
Division of
Corporation Finance
June 28, 2024 Page 2 Office of
Finance
FirstName LastName