0000036146-14-000099.txt : 20141023 0000036146-14-000099.hdr.sgml : 20141023 20140922120253 ACCESSION NUMBER: 0000036146-14-000099 CONFORMED SUBMISSION TYPE: CORRESP PUBLIC DOCUMENT COUNT: 1 FILED AS OF DATE: 20140922 FILER: COMPANY DATA: COMPANY CONFORMED NAME: TRUSTMARK CORP CENTRAL INDEX KEY: 0000036146 STANDARD INDUSTRIAL CLASSIFICATION: NATIONAL COMMERCIAL BANKS [6021] IRS NUMBER: 640471500 STATE OF INCORPORATION: MS FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 248 E CAPITOL ST STREET 2: P O BOX 291 CITY: JACKSON STATE: MS ZIP: 39201 BUSINESS PHONE: 6013545111 MAIL ADDRESS: STREET 1: 248 EAST CAPITOL STREET CITY: JACKSON STATE: MS ZIP: 39201 FORMER COMPANY: FORMER CONFORMED NAME: FIRST CAPITAL CORP DATE OF NAME CHANGE: 19900513 CORRESP 1 filename1.htm corresp.htm
Covington & Burling LLP
 
BEIJING    BRUSSELS    LONDON    NEW YORK
 
BRUCE C. BENNETT
SAN DIEGO    SAN FRANCISCO    SEOUL   
 
 
SHANGHAI    SILICON VALLEY    WASHINGTON
 
THE NEW YORK TIMES BUILDING
   
620 EIGHTH AVENUE
 
 
NEW YORK, NY 10018-1405
 
 
 
   
T 212.841.1060
   
bbennett@cov.com
 
 
  September 22, 2014
 
 
Mr. Todd K. Schiffman
Ms. Jessica Livingston
Division of Corporation Finance
Securities and Exchange Commission
100 F Street, N.E.
Washington, DC  20549
 
Trustmark Corporation
File No. 000-03683
Form 10-K for the fiscal year ended December 31, 2013


Ladies and Gentlemen:
 
On behalf of our client, Trustmark Corporation (“Trustmark”), we submit the following response to the comment on the above-referenced Form 10-K for the fiscal year ended December 31, 2013 (the “2013 Form 10-K”).  The comment was contained in the Staff’s letter to Trustmark dated September 18, 2014, responding to supplemental materials filed by Trustmark on August 27, 2014.
 
Prior Comment 5:  We note your response and restate the comment.  Although you have identified the Principal Accounting Officer in the first signature block, the Principal Financial Officer and Principal Accounting Officer must also sign on behalf of the registrant in the second signature block.  Please amend the second signature block where the 10-K is signed on behalf of the registrant to include the Principal Financial Officer and either the Principal Accounting Officer or the Controller, as required by General Instruction D(2)(a) of Form 10-K.
 
 
 

 
Response to Prior Comment 5:
 
In the first signature block for future filings of Form 10-K, a single authorized officer will sign on behalf of Trustmark.  We confirm that the signature of a single authorized officer will bind Trustmark for purposes of execution and delivery of the Form 10-K.  In the second signature block for future filings of Form 10-K, the Chief Executive Officer, the Principal Financial Officer and the Principal Accounting Officer, as well as at least a majority of the board of directors, will sign the Form 10-K.  As you know, the positions of Principal Financial Officer and Principal Accounting Officer at Trustmark are currently held by the same person (Louis Greer).
 
* * * * *
 
Trustmark has authorized us to confirm, on its behalf, to the Staff the following with respect to its 2013 Form 10-K:
 
·  
Trustmark is responsible for the adequacy and accuracy of the disclosure in the 2013 Form 10-K;
 
·  
Staff comments or changes to disclosure in response to Staff comments do not foreclose the Commission from taking any action with respect to the 2013 Form 10-K; and
 
·  
Trustmark may not assert Staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.
 
Should you have any questions regarding this response, please contact the undersigned at 212.841.1060 or at bbennett@cov.com, or contact Louis Greer, Treasurer, Principal Financial Officer and Principal Accounting Officer of Trustmark, at 601.208.2310 or at lgreer@trustmark.com.
                          
 
  Sincerely, 
   
  /s/ Bruce C. Bennett
   
  Bruce C. Bennett 
 
 
cc:  Mr. Gerard R. Host 
 
Mr. Louis E. Greer
  Mr. T. Harris Collier, III 
      Trustmark Corporation 
   
  Mr. R. Michael Summerford 
      Chair of the Audit and Finance Committee of Trustmark Corporation