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C. Robert Monroe
PARTNER
DIRECT: 816.691.3351
OFFICE: 816.842.8600
bob.monroe@stinson.com
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July 18, 2019
Via EDGAR
Securities and Exchange Commission
Division of Corporation Finance
100 F Street, N.E.
Washington, D.C. 20549
Attn:
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Jessica Livingston
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Office of Financial Services
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Re:
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CrossFirst Bankshares, Inc.
Registration Statement on Form S-1
CIK No. 0001458412
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Ladies and Gentlemen,
On behalf of CrossFirst Bankshares, Inc., a Kansas corporation (the “Company”), we are filing a Registration Statement on Form S-1 (the “Registration Statement”) with the Securities and Exchange Commission (the “SEC”) in connection with a proposed
initial public offering of shares of the Company’s common stock, par value $0.01 per share. The Company confirms that it is an “emerging growth company” as defined in the Jumpstart Our Business Startups Act, as amended, and its securities have not
been previously sold pursuant to an effective registration statement under the Securities Act of 1933, as amended (the “Securities Act”).
For your reference, copies of this letter, along with both clean copies of the Registration Statement and copies marked to show all changes from Amendment No. 2 to Draft Registration Statement on Form S-1, which was confidentially submitted by the
Company to the SEC on May 9, 2019 (the “Draft Registration Statement”), are being separately provided to the staff of the Division of Corporation Finance (the “Staff”) of the SEC.
In addition to revisions necessary to file the Registration Statement with the SEC, including the addition of filing fee information, signatures and exhibits, the Registration Statement also includes other changes that are intended to update and
clarify the information contained therein, including updating information regarding the number of shares of the Company’s common stock outstanding and beneficial ownership of such shares and updating certain other information. We have generally not
updated the financial statements or financial information in the Registration Statement. We currently intend to file a Pre-Effective Amendment No. 1 to the Registration Statement with the SEC on or about July 29, 2019 to (i) add the Company’s
unaudited financial statements as of and for the six months ended June 30, 2019 and 2018, (ii) provide certain disclosure with respect to the three and six month periods ended June 30, 2019 and 2018, and (iii) update certain pie charts and other
charts and graphics to provide information as of or for the three and six month periods ended June 30, 2019.
1201 Walnut Street, Suite 2900, Kansas City, MO 64106
Securities and Exchange Commission
July 18, 2019
Page 2
If you or any member of the Staff has any questions regarding the foregoing, or desires further information or clarification in connection therewith, please contact the undersigned by phone at 816.691.3351 or via email at bob.monroe@stinson.com
or Scott Gootee of our office by phone at 816.691.3263 or via email at scott.gootee@stinson.com.
Sincerely,
Stinson LLP
/s/ C. Robert Monroe
C. Robert Monroe
cc:
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Pamela Long
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John Nolan
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Christina Harley
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Securities and Exchange Commission
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David O’Toole, Chief Financial Officer, CrossFirst Bankshares, Inc.
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Aisha Reynolds, General Counsel & Corporate Secretary, CrossFirst Bankshares, Inc.
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