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August 2, 2005
Mail Stop 4561
By U.S. Mail and facsimile to (909) 481-2120
Mr. Edward J. Biebrich, Jr.
Chief Financial Officer
CVB Financial Corp.
701 N. Haven Avenue, Suite 350
Ontario, CA 91764
Re: CVB Financial Corp.
Form 10-K for Fiscal Year Ended December 31, 2004
File No. 000-10140
Dear Mr. Biebrich:
We have limited our review of your filing to the issue we
have
addressed in our comment. Where indicated, please provide us with
the
supplemental documentation we requested in response to this
comment.
Please be as detailed as necessary in your explanation. After
reviewing this information, we may or may not raise additional
comments.
Please understand that the purpose of our review process is
to
assist you in your compliance with the applicable disclosure
requirements and to enhance the overall disclosure in your filing.
We look forward to working with you in these respects. We welcome
any questions you may have about our comments or any other aspect
of
our review. Feel free to call us at the telephone numbers listed
at
the end of this letter.
Form 10-K
Notes to Consolidated Financial Statements
Note 2 - Investment Securities, page 69
1. We note that you recorded in the first quarter of 2004 a $6.3
million other-than-temporary impairment relating to your FHLMC
perpetual preferred stock investments. At December 31, 2004 and
2003
the unrealized loss positions on these investments were $5.6
million
and $2.7 million, respectively. Please tell us how you were able
to
conclude that no other-than-temporary impairment relating to your
FHLMC perpetual preferred stock investments existed as of these
dates. Your response should included but not be limited to the
quantifications supporting how you determined the recognized $6.3
million impairment, details for both periods including name of
security, purchase date and price, current amortized cost, and any
other information you consider in your periodic analysis. Please
refer to the specific relevant guidance in SFAS No.115 and SAB
Topic
5:M in your response.
* * * * *
As appropriate, please respond to this comment within 10
business days or tell us when you will provide us with a response.
Please furnish a cover letter that keys your responses to our
comment
and provides any requested supplemental information. Detailed
cover
letters greatly facilitate our review. Please understand that we
may
have additional comments after reviewing your amendment and
responses
to our comment.
We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filing reviewed by the staff to
be
certain that they have provided all information required under the
Securities Exchange Act of 1934 and that they have provided all
information investors require for an informed investment decision.
Since the company and its management are in possession of all
facts
relating to a company`s disclosure, they are responsible for the
accuracy and adequacy of the disclosures they have made.
In connection with responding to our comment, please provide,
in
writing, a statement from the company acknowledging that:
* the company is responsible for the adequacy and accuracy of the
disclosure in the filing;
* staff comments or changes to disclosure in response to staff
comments do not foreclose the Commission from taking any action
with
respect to the filing; and
* the company may not assert staff comments as a defense in any
proceeding initiated by the Commission or any person under the
federal securities laws of the United States.
In addition, please be advised that the Division of
Enforcement
has access to all information you provide to the staff of the
Division of Corporation Finance in our review of your filing or in
response to our comments on your filing.
You may contact Paula Smith (Staff Accountant) at (202) 551-
3696
or me at (202) 551-3492 if you have any questions regarding
comments
on the financial statements and related matters.
Sincerely,
John P. Nolan
Accounting Branch Chief
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Edward J. Biebrich, Chief Financial Officer
CVB Financial Corp.
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