TEXT-EXTRACT 2 filename2.txt November 14, 2019 Bradley M. Rust Executive Vice President and Chief Financial Officer German American Bancorp, Inc. 711 Main Street Jasper, Indiana 47546 Re: German American Bancorp, Inc. Form 10-K for the Fiscal Year Ended December 31, 2018 Filed March 1, 2019 Form 10-Q for the Quarterly Period Ended September 30, 2019 Filed November 8, 2019 File No. 001-15877 Dear Mr. Rust: We have reviewed your filings 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-Q for the Quarterly Period Ended September 30, 2019 Notes to Consolidated Financial Statements Note 15 - Business Combinations, page 41 1. We note that you completed the acquisitions of Citizens First Corporation ("Citizens First") on July 1, 2019, as disclosed on page 41 of your Form 10-Q, and of First Security, Inc. ("First Security") on October 15, 2018, as disclosed on page 88 of your Form 10-K for the fiscal year ended December 31, 2018. However, it is not clear where you have disclosed all the information required by ASC 805 for these acquisitions, such as the amounts of post-acquisition revenues and earnings or supplemental pro forma revenues and earnings required by ASC 805-10-50-2(h). In your future filings, please revise to disclose all information required by ASC 805-10-50 for these acquisitions or tell us why you do not think it is required. Bradley M. Rust German American Bancorp, Inc. November 14, 2019 Page 2 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 Lory Empie, Staff Accountant, at (202) 551-3714 or Robert Klein, Staff Accountant, at (202) 551-3847 if you have questions. FirstName LastNameBradley M. Rust Sincerely, Comapany NameGerman American Bancorp, Inc. Division of Corporation Finance November 14, 2019 Page 2 Office of Finance FirstName LastName