September 13, 2024
Jamie L. Prah
Chief Financial Officer
CB Financial Services, Inc.
100 North Market Street
Carmichaels, PA 15320
Re: CB Financial Services, Inc.
Form 10-K for Fiscal Year Ended December 31, 2023
File No. 001-36706
Dear Jamie L. Prah:
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 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 Composition, page 35
1. We note, based on the tabular disclosure on page 35, that commercial
real estate ( CRE )
loans appear to be approximately 42% of your loan portfolio as of
December 31, 2023.
Given the proportion of CRE loans in your portfolio, please revise
future filings to
disaggregate these loans by owner-occupied and non-owner occupied and by
key
borrower type (e.g., multifamily, warehouse, office, retail, etc.). This
could be similar to
the detail you provide on slide 18 of your investor presentation in
Exhibit 99.2 of your
Form 8-K dated July 24, 2024. In addition, to the extent that there are
geographic
concentrations in your market areas or other material characteristics
(e.g., current
weighted average and/or range of loan-to-value ratios, occupancy rates,
etc.) that could be
material to an investor s understanding of these loans, include those
details. Finally, if
applicable, revise future filings to describe specific details of any
risk management
policies, procedures, or other actions undertaken by management in
response to the
current environment.
September 13, 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 Mengyao Lu at 202-551-3471 or Cara Lubit at 202-551-5909
with any
questions.
Sincerely,
Division of
Corporation Finance
Office of Finance