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United States securities and exchange commission logo
November 16, 2023
Dean Y. Shigemura
Chief Financial Officer
Bank of Hawaii Corporation
130 Merchant Street
Honolulu, HI 96813
Re: Bank of Hawaii
Corporation
Form 10-K for
Fiscal Year Ended December 31, 2022
Form 10-Q for
Fiscal Quarter Ended June 30, 2023
Form 10-Q for
Fiscal Quarter Ended September 30, 2023
Response dated
October 26, 2023
File No. 001-06887
Dear Dean Y. Shigemura:
We have reviewed your
filing 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.
Quarterly Report on Form 10-Q for Fiscal Quarter Ended September 30,
2023
Management's Discussion and Analysis of Financial Condition and Results
of Operations
Interest Rate Risk, page 62
1. We note the response to
our prior comment 3 and the disclosure on pages 62 and 63 in
the Form 10-Q for the
Quarterly Period Ended September 30, 2023. We note your net
interest income
sensitivity disclosures in Table 17 only disclose the impacts within a -200
basis points to a +200
basis points range; however, your disclosure on page 62 and
response addresses a
-400 basis points to a +400 basis points range used by management.
Please confirm that you
will revise your future filings to include a sensitivity analysis
ranging from -400 basis
points to +400 basis points.
2. We note your disclosure
on page 62 that you also measure your interest rate exposure
using economic value of
equity ("EVE") sensitivity. Please confirm that you will revise
your future filings to
include qualitative discussion of how EVE is utilized to manage your
Dean Y. Shigemura
Bank of Hawaii Corporation
November 16, 2023
Page 2
interest rate risk exposure. To the extent it is used by management,
disclose quantitative
EVE sensitivity information in your future filings.
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 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
November 16, 2023 Page 2
cc: Patrick M. McGuirk, Esq.
FirstName LastName