Mail Stop 4720
August 22,
2018
Alan W. Jackson
Executive Vice President and
Chief Financial Officer
Capital Bancorp, Inc.
One Church Street
Rockville, MD 20850
Re: Capital Bancorp, Inc.
Amendment No. 3 to
Draft Registration Statement on Form S-1
Submitted August 20, 2018
CIK No. 0001419536
Dear Mr. Jackson:
We have reviewed your amended draft registration statement and have
the following
comments. In some of our comments, we may ask you to provide us with
information so we
may better understand your disclosure.
Please respond to this letter by providing the requested
information and either submitting
an amended draft registration statement or publicly filing your
registration statement on
EDGAR. If you do not believe our comments apply to your facts and
circumstances or do not
believe an amendment is appropriate, please tell us why in your response.
After reviewing the information you provide in response to these
comments and your
amended draft registration statement or filed registration statement, we
may have additional
comments.
Selected Historical Consolidated Financial and Other Data
GAAP Reconciliation and Management Explanation of Non-GAAP Financial
Measures, page 17
1. We note that you have titled several of your non-GAAP measures as
"pro forma." Based
on the information in the filing, it does not appear that this
information is pro forma
financial information based on the guidance in Article 11 of
Regulation S-X. If true,
please revise your presentation to more clearly present your
non-GAAP measures
eliminating the use of the words pro forma.
Alan W. Jackson
Capital Bancorp, Inc.
August 22, 2018
Page 2
You may contact William Schroeder, Staff Accountant, at (202) 551-3294
or Michael
Volley, Staff Accountant, at (202) 551-3437 if you have questions regarding
comments on the
financial statements and related matters. Please contact Christopher Dunham,
Staff Attorney, at
(202) 551-3783 or, in his absence, me at (202) 551-3765 with any other
questions.
Sincerely,
/s/ Pamela A. Long
Pamela A. Long
Assistant Director
Office of Financial
Services
cc: William H. Levay, Esq.