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United States securities and exchange commission logo
September 27, 2023
Dean Y. Shigemura
Chief Financial Officer
Bank of Hawaii Corporation
130 Merchant Street
Honolulu, HI 96813
Re: Bank of Hawaii
Corporation
Annual Report on
Form 10-K for Fiscal Year Ended December 31, 2022
Filed March 1, 2023
Quarterly Report on
Form 10-Q for Fiscal Quarter Ended June 30, 2023
Filed July 25, 2023
File No. 001-06887
Dear Dean Y. Shigemura:
We have reviewed your filing 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.
Annual Report on Form 10-K for Fiscal Year Ended December 31, 2022
Management s Discussion and Analysis of Financial Condition and
Results of Operations
Interest Rate Risk, page 43
1. We note the statement
on page 44 that you use an asset/liability simulation model to
monitor interest rate
risk, and the model contains a number of assumptions, including
those related to the
behavior of loan and deposit pricing, prepayment rates on mortgage-
based assets, principal
amortization and maturities on other financial instruments, as well
as effects of standard
prepayment options on mortgages and customer withdrawal options
for deposits. Your
disclosure also states that while the assumptions are inherently
uncertain, you believe
your assumptions are reasonable. Please tell us and revise future
filings to disclose the
key assumptions and parameters which are necessary to understand
the disclosure made for
purposes of your interest rate sensitivity analysis. Additionally,
Dean Y. Shigemura
FirstName LastNameDean
Bank of Hawaii CorporationY. Shigemura
Comapany 27,
September NameBank
2023 of Hawaii Corporation
September
Page 2 27, 2023 Page 2
FirstName LastName
you should provide a discussion of the changes in the outputs in the
analysis from period
to period and the factors driving the changes. See Item
305(a)(1)(ii)(B) of Regulation S-
K.
2. We note your disclosure on page 44 that your ALCO utilizes several
techniques to
manage interest rate risk, and that your use of derivatives has
generally been limited due
to the natural on-balance sheet hedges arising out of offsetting
interest rate exposures from
loans and investment securities with deposits and other
interest-bearing liabilities. To the
extent used to manage interest rate risk, consider disclosing:
Repricing risk analysis or gap analysis to illustrate how
differences in the timing of
when assets, liabilities, and off-balance sheet instruments
re-price to market rates or
another rate.
Duration disclosure, including a discussion of the key inputs
and assumptions for the
estimate of duration and drives of the change in duration from
period to period.
3. We note the statement on page 43 that your interest rate risk
management process is to
optimize net interest income while operating within acceptable
limits established for
interest rate risk and maintaining adequate levels of funding and
liquidity. Please provide
draft disclosure and revise future filings to include a materially
complete description of
how you seek to manage risks due to changes in interest rates and
other material impacts
on your operational facts and circumstances, including any management
or corporate
governance controls or procedures for identifying and responding to
rapid changes in
interest rates due to or as a result of exogenous or unknown factors.
For example, it is
unclear what acceptable limits, liquidity policy guidelines and
other metrics were used
by the ALCO and/or other committees to manage interest rate risk and
liquidity. It is also
unclear whether you were in compliance with the acceptable limits or
other material
internal guidelines. If not in compliance, discuss here or in the
Liquidity Risk
Management section, any planned actions to be taken.
Quarterly Report on Form 10-Q for Fiscal Quarter Ended June 30, 2023
Management's Discussion and Analysis of Financial Condition and Results of
Operations
Liquidity Risk Management, page 62
4. We note the significant increase in FHLB advances as disclosed on page
54 of the Form
10-Q for the quarter ended June 30, 2023. The Form 10-Q also addresses
a possible
increase in the cost of funding on page 66. In future filings, please
expand your
Management s Discussion and Analysis to clarify trends and
uncertainties related to
financial performance and liquidity. In this regard, discuss the
parameters to access
sources of liquidity and the extent to which accessing such funding
sources would involve
realizing material losses or other potential consequences, such as
dividend restrictions or
limits on stock repurchases. Please provide draft disclosure.
Dean Y. Shigemura
Bank of Hawaii Corporation
September 27, 2023
Page 3
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 Michael Henderson at 202-551-3364 or Marc Thomas at
202-551-
3452 if you have questions regarding comments on the financial statements and
related
matters. Please contact Tonya Aldave at 202-551-3601 or Todd Schiffman at
202-551-3491 with
any other questions.
Sincerely,
FirstName LastNameDean Y. Shigemura
Division of
Corporation Finance
Comapany NameBank of Hawaii Corporation
Office of Finance
September 27, 2023 Page 3
cc: Patrick M. McGuirk, Esq.
FirstName LastName