August 23, 2024
Justin Clausen
Chief Financial Officer
Ames National Corporation
405 Fifth Street
Ames, IA 50010
Re: Ames National Corporation
Form 10-K for Fiscal Year Ended December 31, 2023
File No. 000-32637
Dear Justin Clausen:
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
The commercial real estate loan portfolio is a significant part of the
Company's business and
subject to the risk of fluctuating..., page 17
1. We note your disclosure on page 17 that the market value of real estate
securing your
commercial real estate loans can fluctuate significantly in a short
period of time as a result
of market conditions and that adverse developments affecting real
estate values in one
or more of your markets could increase the credit risk associated with
your loan portfolio.
Please revise your future periodic filings to describe the specific
details of any risk
management policies, procedures or other actions undertaken by
management in response
to the current multi-family and commercial real estate environment.
Maturities and Sensitivities of Loans to Changes in Interest Rates as of
December 31, 2023, page
38
2. We note that, based on your contractual maturities table as presented on
page 38, the
combination of your commercial real estate and multi-family loan
portfolios comprised
approximately 42.9% of total gross loans as of December 31, 2023. We
further note your
August 23, 2024
Page 2
disclosure on page 69 that multi-family and commercial real estate
lending typically
involves higher loan principal amounts and that the repayment of these
loans may be
subject to adverse conditions in the real estate market or the economy.
Please revise your
future periodic filings to further disaggregate the composition of these
loan portfolios to
disclose and quantify material geographic and industry concentrations
(e.g., office, retail
and hotel), as well as owner-occupied/non-owner-occupied, current
weighted average
and/or range of loan-to-value ratios and occupancy rates, if available,
to enhance an
investor s understanding of the credit risk inherent in these loan
categories.
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 William Schroeder at
202-551-3294
with any questions.
Sincerely,
Division of
Corporation Finance
Office of Finance