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United States securities and exchange commission logo
July 15, 2022
Dean Y. Shigemura
Vice Chair, Chief Financial Officer and Principal Accounting Officer
Bank of Hawaii Corporation
130 Merchant Street
Honolulu, Hawaii 96813
Re: Bank of Hawaii
Corporation
Form 10-K for the
Fiscal Year Ended December 31, 2021
Filed March 1, 2022
File No. 001-06887
Dear Mr. Shigemura:
We have limited our review of your filing to the financial
statements and related
disclosures and have the following comments. In some of our comments, we
may ask you to
provide us with information so we may better understand your disclosure.
Please respond to these comments 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 our
comments apply to your facts and circumstances, please tell us why in
your response.
After reviewing your
response to these comments, we may have additional comments.
Form 10-K for the Fiscal Year Ended December 31, 2021
Management's Discussion and Analysis of Financial Condition and Results
of Operations
Critical Accounting Policies
Reserve for Credit Losses, page 21
1. You disclose that your
estimate of expected credit losses on loans and leases is based on
relevant information
about past events, current conditions, and reasonable and supportable
forecasts that affect
the collectability of the reported amounts. You also disclose that your
reserve for unfunded
commitments is determined by estimating future draws and applying
the expected loss rates
on those draws. Please provide us proposed revised disclosure to
be included in future
filings that:
Identifies the key
quantitative inputs used in your estimate of the allowance for
credit losses and
reserve for unfunded commitments;
Indicates and
quantifies how these key quantitative inputs changed from period to
period;
Dean Y. Shigemura
Bank of Hawaii Corporation
July 15, 2022
Page 2
Quantifies the qualitative component of your estimate and how
it interacts with
the quantitative component during the period; and
Provides a sensitivity analysis of the impact on the current
estimate of reasonably
likely changes in the key quantitative inputs.
To the extent appropriate, consider integrating your discussion of the
Hawaiian economy
disclosed on page 23 and your outlook as presented and discussed on
slides 3 through 5 of
your earnings call for the fourth quarter of 2021 held on January 24,
2022 into your
response and future disclosures. See Item 303(b)(3) of Regulation S-K.
Loans and Leases, page 33
2. Please represent to us that, in future filings, you will provide the
maturity disclosures,
including providing an over 15 year category, if appropriate for each
loan category
presented in your financial statements as required by Item 1404(a) of
Regulation S-K.
Otherwise, tell us why it is appropriate to include this information
for only your
Commercial and Industrial loans and leases and your Construction loans
and leases as
presented in Table 10 on page 35.
3. We note that you provide aggregated fixed rate versus variable rate
information for the
loan categories presented in Table 10. Please represent to us that, in
future filings, you
will provide this disclosure for each category of loans presented in
your financial
statements as required by Item 1404(b) 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.
You may contact Mark Brunhofer at 202-551-3638 or Sharon Blume at
202-551-
3474 with any questions.
FirstName LastNameDean Y. Shigemura Sincerely,
Comapany NameBank of Hawaii Corporation
Division of
Corporation Finance
July 15, 2022 Page 2 Office of
Finance
FirstName LastName