July 18, 2024
Troy Adair
Executive Vice President, Secretary and Chief Financial Officer
Farmers National Banc Corp.
20 South Broad Street
Canfield, OH 44406
Re: Farmers National Banc Corp.
Form 10-K for Fiscal Year Ended December 31, 2023
File No. 001-35296
Dear Troy Adair:
We have limited our review of your filing to the financial statements
and related
disclosures 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.
Form 10-K for Fiscal Year Ended December 31, 2023
Item 7. Management's Discussion and Analysis of Financial Condition and Results
of Operations
Loan Portfolio, page 36
1. We note your tabular disclosure on page 36 which indicates that your
commercial real
estate ( CRE ) loan portfolio comprised 41.6% of total net loans as
of December 31,
2023. We also note disclosure in Exhibit 99.2 of your Form 8-K filed on
January 24, 2024
that provides detailed disclosures of your CRE loan portfolio as of
December 31, 2023.
Please revise future filings to further disaggregate the composition of
your CRE loan
portfolio to disclose and quantify material geographic and industry
concentrations (e.g.,
office, retail, hotel and multifamily), as well as current weighted
average and/or range of
loan-to-value ratios and occupancy rates to enhance an investor s
understanding of these
loan categories. See Item 303 of Regulation S-K.
Item 7A. Quantitative and Qualitative Disclosures About Market Risk, page 49
2. We note the discussion in which you disclose plans to prioritize loan
growth in response
to exceeding internal policy limits for Economic Value of Equity derived
from simulation
July 18, 2024
Page 2
analysis used to manage interest rate risk in up rate scenarios
explained in conjunction
with your related tabular information. We also note your disclosure on
page 18 that
certain loans including real estate-related credit risks are a
significant concern for you.
Please revise future filings to describe the specific details of any
risk management
policies, procedures or other actions undertaken by management to
address management's
noted plans to expand loan growth despite credit risk concerns, and in
response to the
current environment. We note Item 305 of Regulation S-K.
General
3. We note that the consent of your independent registered public
accounting firm, which
was filed as Exhibit 23.1, did not include a date for Crowe LLP s
audit report. Please
revise or advise.
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.
Please contact Shannon Davis at 202-551-6687 or John Nolan at
202-551-3492 with any
questions.
Sincerely,
Division of
Corporation Finance
Office of Finance