[First Hawaiian, Inc. Letterhead]
August 1, 2016
Via E-mail and EDGAR
Securities and Exchange Commission,
Division of Corporation Finance,
100 F. Street, N.E.,
Washington, D.C. 20549.
Attention: Christopher Dunham
Re: Acceleration Request for First Hawaiian, Inc.
Registration Statement on Form S-1 (File No. 333-212451)
Ladies and Gentlemen:
Pursuant to Rule 461 under the Securities Act of 1933, as amended, First Hawaiian, Inc. (the Company), hereby requests that the effective date of the Companys Registration Statement on Form S-1, Registration Number 333-212451 (the Registration Statement) be accelerated so that the Companys Registration Statement will become effective at 4:00 PM, Washington, D.C. time, on August 3, 2016, or as soon thereafter as practicable. In this regard, the Company is aware of its obligations under the Securities Act as they relate to the above-referenced Registration Statement and acknowledges:
· should the Securities and Exchange Commission (the SEC) or its staff (the Staff), acting pursuant to delegated authority, declare the Registration Statement effective, it does not foreclose the Commission from taking any action with respect to the Registration Statement;
· the action of the Commission or the Staff, acting pursuant to delegated authority, in declaring the Registration Statement effective, does not relieve the Company from its full responsibility for the adequacy and accuracy of the disclosure in the Registration Statement; and
· the Company may not assert Staff comments and the declaration of the Registration Statements effectiveness as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.
* * *
It would be appreciated if, as soon as the Registration Statement is declared effective, you would so inform Catherine M. Clarkin at Sullivan & Cromwell LLP at (212) 558-4175.
|
Very truly yours, | ||
|
|
| |
|
First Hawaiian, Inc. | ||
|
|
| |
|
|
| |
|
By: |
/s/ Robert S. Harrison | |
|
|
Name: |
Robert S. Harrison |
|
|
Title: |
Chairman and Chief Executive |
|
|
|
Officer |
Goldman, Sachs & Co.
200 West Street
New York, NY 10282-2198
Merrill Lynch, Pierce, Fenner & Smith Incorporated
One Bryant Park
New York, NY 10036
BNP Paribas Securities Corp.
787 Seventh Avenue
New York, NY 10019
August 1, 2016
U.S. Securities and Exchange Commission
Division of Corporate Finance
100 F Street, N.E.
Washington, D.C. 20549
Attention: Christopher Dunham
Re: First Hawaiian Inc. (the Company)
Registration Statement on Form S-1 (File No. 333-212451)
Ladies and Gentlemen:
Pursuant to Rule 461 under the Securities Act of 1933, as amended (the Securities Act), we hereby join the Companys request for acceleration of the above-referenced Registration Statement, requesting effectiveness of 4:00 p.m. New York City time on August 3, 2016, or as soon thereafter as is practicable.
Pursuant to Rule 460 of the General Rules and Regulations promulgated under the Securities Act of 1933, as amended, we wish to advise you that we have effected the following distribution of the Companys Preliminary Prospectus dated July 26, 2016, through the date hereof:
Preliminary Prospectus dated July 26, 2016:
3,353 copies to prospective Underwriters, institutional investors, dealers and others.
The undersigned advise that the underwriters have complied and will continue to comply with Rule 15c2-8 under the Securities Exchange Act of 1934, as amended.
[Signature Pages Follow]
|
Very truly yours, | |
|
| |
|
GOLDMAN, SACHS & CO. | |
|
| |
|
| |
|
By: |
/s/ Richard Cohn |
|
Name: |
Richard Cohn |
|
Title: |
Managing Director |
First Hawaiian, Inc. IPO Signature Page to Underwriter Acceleration Request
|
MERRILL LYNCH, PIERCE, FENNER & SMITH INCORPORATED | |
|
| |
|
| |
|
By: |
/s/ Michael Liloia |
|
Authorized Signatory |
First Hawaiian, Inc. IPO Signature Page to Underwriter Acceleration Request
|
BNP PARIBAS SECURITIES CORP. | |
|
| |
|
|
|
|
By: |
/s/ Pierre Lapomme |
|
Name: |
Pierre Lapomme |
|
Title: |
Managing Director |
First Hawaiian, Inc. IPO Signature Page to Underwriter Acceleration Request