View:
United States securities and exchange commission logo
August 12, 2020
David Morris
Chief Financial Officer
RBB Bancorp
1055 Wilshire Boulevard
Suite 1200
Los Angeles, California 90017
Re: RBB Bancorp
Form 10-K for
Fiscal Year Ended December 31, 2019
Filed March 17,
2020
File No. 001-38149
Dear Mr. Morris:
We have limited our review of your filing to the financial
statements and related
disclosures and have the following comment. In our comment, we may ask
you to provide us
with information so we may better understand your disclosure.
Please respond to this comment 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
comment applies to your facts and circumstances, please tell us why in
your response.
After reviewing your
response to this comment, we may have additional comments.
Form 10-K for Fiscal Year Ended December 31, 2019
Risks Related to an Investment in Our Common Stock, page 48
1. We note disclosure on
page 51 that as a result of being an emerging growth company, you
are permitted to take
advantage of an extended transition period to comply with new or
revised accounting
standards applicable to public companies but that you have irrevocably
"opted out" of this
provision and will comply with new or revised accounting standards to
the same extent that
compliance is required for public business entities. We note similar
disclosure on page 46
of your Form S-1, filed on June 28, 2017. We also note disclosure
regarding the adoption
of recent accounting pronouncements that indicates that you have
or will adopt the new
standard using extended transition dates (e.g. ASU 2016-13). Please
identify for us each
material new or revised accounting standard that should have been
adopted by public
business entities during 2017, 2018, 2019 or 2020 and tell us the
transition provisions
you used to adopt the standard, i.e., early adopted, adopted using
David Morris
RBB Bancorp
August 12, 2020
Page 2
effective dates applicable to a public business entity, or adopted (or
plan to adopt) using
an extended transition period available to an emerging growth company.
If you have not
adopted the standard using effective dates applicable to a public
business entity, please tell
us how your current accounting policies and disclosure are consistent
with US GAAP
since your election to opt out of the extended transition period is
irrevocable pursuant to
Section 107(b)(3) of the JOBS Act. Please refer to Question 13 of the
Jumpstart Our
Business Startups Act Frequently Asked Questions available
at
https://www.
sec.gov/divisions/corpfin/guidance/cfjjobsactfaq-title-i-general.htm.
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 John Spitz, Staff Accountant, at (202) 551-3484 or
Michael Volley,
Staff Accountant, at (202) 551-3437 with any questions.
FirstName LastNameDavid Morris Sincerely,
Comapany NameRBB Bancorp
Division of
Corporation Finance
August 12, 2020 Page 2 Office of
Finance
FirstName LastName