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United States securities and exchange commission logo
December 18, 2023
Terry Earley
Chief Financial Officer
Veritex Holdings, Inc.
8214 Westchester Drive, Suite 800
Dallas, TX 75225
Re: Veritex Holdings,
Inc.
Form 10-Q for
Fiscal Quarter Ended September 30, 2023
File No. 001-36682
Dear Terry Earley:
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-Q for Fiscal Quarter Ended September 30, 2023
Item 2. Management's Discussion and Analysis of Financial Condition and
Results of Operations
General, page 46
1. We note that recent
quarterly earnings calls and investor presentations address operational
efforts regarding, and
trends in, commercial real estate, interest rate sensitivity, deposit
costs ( rate hike
beta trends ) and actions designed to reposition the balance sheet.
However, we note the
Recent Industry Developments and other sections of
Management s
Discussion and Analysis do not identify or provide explanations regarding
these topics. Please
revise future filings to identify and explain such operational efforts
and trends where
material, and further clarify material changes in your deposit base and
funding costs that are
likely to result in your liquidity or funding costs increasing or
decreasing in any
material way.
Loan Portfolio, page 58
2. We note the tabular
disclosure detailing the composition of your gross loan portfolio,
which includes both
owner-occupied commercial real estate ( OOCRE ) and non-owner
Terry Earley
Veritex Holdings, Inc.
December 18, 2023
Page 2
occupied commercial real estate ( NOOCRE ) as well as Construction
and Land. Given
the significance of these loan categories to your total loan
portfolio, please revise your
disclosures, in future filings, to further disaggregate the
composition of your CRE and
Construction and Land loan portfolios by borrower type (e.g., by
office, hotel,
multifamily, etc. for CRE loans), geographic concentrations and other
characteristics as
applicable (e.g., current weighted average and/or range of
loan-to-value ratios, occupancy
rates, etc.) material to an investor's understanding of these loan
portfolios. In addition,
revise to describe the specific details of any risk management
policies, procedures or other
actions undertaken by management in response to the current
environment.
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 John Spitz at 202-551-3484 or Amit Pande at 202-551-3423
with any
questions.
FirstName LastNameTerry Earley Sincerely,
Comapany NameVeritex Holdings, Inc.
Division of
Corporation Finance
December 18, 2023 Page 2 Office of
Finance
FirstName LastName