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United States securities and exchange commission logo
May 3, 2024
Peter Chapman
Executive Vice President and Chief Financial Officer
HBT Financial, Inc.
401 North Hershey Rd
Bloomington, Illinois 61704
Re: HBT Financial, Inc.
Form 10-K for the
Fiscal Year Ended December 31, 2023
File No. 001-39085
Dear Peter Chapman:
We have limited our review of your filing to the financial
statements and related
disclosures and have the following comment(s).
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 the Fiscal Year Ended December 31, 2023
Item 1. Business
Concentrations in Commercial Real Estate, page 17
1. We note your
disclosures regarding risk management practices related to commercial real
estate lending. Please
revise future filings, here or elsewhere as appropriate, to describe
specific details of any
key risk management policies, procedures, or other actions
undertaken by
management in response to the current environment.
Management's Discussion and Analysis of Financial Condition and Results
of Operations
Loan Portfolio, page 56
2. We note the tabular
disclosure on page 56 detailing the composition of your gross loan
portfolio, which
includes commercial real estate ( CRE ) disaggregated by owner and
non-owner occupied
loans. Given the significance of CRE to your total loan portfolio,
please revise your
disclosures in future filings to further disaggregate owner and non-
owner occupied CRE loan
composition by separately presenting the components of the
portfolio by key
borrower type (e.g., by office, retail, multi-family, etc.). This could be
Peter Chapman
HBT Financial, Inc.
May 3, 2024
Page 2
similar to, but not necessarily identical to, detail you provide in
Exhibit 99.2 of your 8-K
dated April 22, 2024. In addition, to the extent that there are other
characteristics (e.g.,
current weighted average and/or range of loan-to-value ratios,
occupancy rates, etc.)
material to an investor s understanding of your CRE loan portfolio,
include those details
in future filings.
Liquidity, page 63
3. We note your disclosures regarding liquidity. In future filings,
please enhance your
disclosures, here or elsewhere as appropriate, to present holistic
tabular disclosure of your
available liquidity sources, including total borrowing capacity,
borrowings outstanding,
and other sources of liquidity (cash, securities, etc.) to arrive at
total available liquidity.
4. We note your disclosure of deposit beta on slide 23 of Exhibit 99.2 in
your 8-K dated
April 22, 2024. To the extent that deposit beta is monitored and used
by management,
please revise future filings such as 10-Qs and 10-Ks to incorporate
disclosures regarding
deposit beta and how you calculate it, either here or in an
appropriate location.
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 Sarmad Makhdoom at 202-551-5776 or Cara Lubit at
202-551-5909 with
any questions.
FirstName LastNamePeter Chapman Sincerely,
Comapany NameHBT Financial, Inc.
Division of
Corporation Finance
May 3, 2024 Page 2 Office of
Finance
FirstName LastName