EX-10 2 stilnecb13d111116am10ex10.htm LETTER TO SECURITIES AND EXCHANGE COMMISSION, DATED NOVEMBER 16, 2011 stilnecb13d111116am10ex10.htm - Generated by SEC Publisher for SEC Filing

Exhibit 10

 

 

 

 

 

 

                                                                                                                                                                                           November 16, 2011

Re: Northeast Community Bancorp, Inc. (NECB) Form 10-Q, filed on November 14, 2011

Dear Ms. Hayes,

     I represent Stilwell Value Partners IV, L.P. and its Schedule 13D filing Group with respect to the issuer NECB. I am writing because NECB mischaracter-ized a legal proceeding in Part II, Item 1 of its Form 10-Q, filed on November 14, 2011.

     NECB disclosed the existence of the lawsuit brought by my client against NECB, its directors, and its largest shareholder. The following statement, however, is untrue: “The complaint alleges that the directors have breached their fiduciary duties by not undertaking a “’second-step’ conversion of the MHC. . . .” The complaint, filed as Exhibit 9 to my client’s Schedule 13D dated October 31, 2011, does not claim that the directors breached their fiduciary duties by not undertaking a second step conversion. Rather, it alleges that the directors breached their fiduciary duties by failing to recuse themselves due to the inherent conflict of interest they face as a result of sitting as directors of the largest shareholder who opposes a second step conversion. (Complaint,¶¶‘s 1-8.) We believe NECB should be required to issue a corrective statement because the current disclosure is untrue and misleading.


Ms. Suzanne Hayes
 Assistant Director
  Division of Corporation Finance
   Securities and Exchange Commission
    100 F Street, NE
     Washington, DC 20549

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