July 31, 2024
Andrew Gregory, Jr.
Executive Vice President and Chief Financial Officer
Synovus Financial Corp.
1111 Bay Avenue
Suite 500
Columbus, GA 31901
Re: Synovus Financial Corp.
Form 10-K for Fiscal Year Ended December 31, 2023
File No. 001-10312
Dear Andrew Gregory Jr.:
We have limited our review of your filing to the financial statements
and related
disclosures and have the following comment.
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
this 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 the fiscal year ended December 31, 2023
Quantitative and Qualitative Disclosures about Market Risk, page 61
1. We note your disclosure on page 26 regarding recent negative
developments affecting the
banking industry that could materially adversely impact your liquidity,
loan funding
capacity, net interest margin, capital, and results of operations. You
state on page 61 that
the company manages interest rate risk in accordance with policies that
are established by
ALCO and approved by the Risk Committee of the Board of Directors. We
also note the
earnings call discussion on July 18, 2024, where regulatory ratios were
discussed as
metrics used in risk management. In your future periodic filings, please
enhance
your disclosures regarding risk management. For example, please describe
any specific
risk management policies, procedures or other actions to address the
current commercial
real estate lending environment, including any established limits for
net interest income
sensitivity as presented in the table on page 61.
July 31, 2024
Page 2
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 Spitz at
202-551-3484 if you have
questions regarding the financial statements and related matters. Please
contact John Stickel
at 202-551-3324 or James Lopez at 202-551-3536 with any other questions.
Sincerely,
Division of
Corporation Finance
Office of Finance