The SEC staff has commented on compliance with mining reserve disclosures pursuant to Regulation S-K 1300, such as requesting expanded disclosures concerning exploration plans and further information on categorization as proven or probable reserves. In addition, the staff has requested supplemental information that establishes technical and economic feasibility of materials designated as reserves as well as their legal ownership.
Comment examples
Guidance references
  • We note your resource and reserve disclosure does not include the price used to determine your economic resources and reserves. See footnote to Table 1 & 2 to Item 1303(b)(3) of Regulation S-K.
  • Please revise to identify the quantity or percentage of resources or reserves attributable to your interests in accordance with Item 1303(b)(3)(iii) of Regulation S-K.
  • Please disclose annual production for your properties for each of the most recently completed fiscal years preceding the filing as required by Item 1303(b)(2)(i) of Regulation S-K.
  • Resource and reserve disclosure is required for each material property pursuant to Item 1304(d)(1) of Regulation S-K. Please include this information with your individual property disclosure or include a reference from within your individual property disclosure identifying where this information is located.
  • We note that a cash flow summary is provided for your various mining projects in the Exhibits. This should also include annual cash flow forecasts that are based on your annual production schedule for the life of the projects, including line items such as revenues, operating costs, capital expenditures, royalties, taxes, and any other items that must be considered in projecting after tax cash flows. See Item 601(b)(96)(iii)(B)(19)(ii) of Regulation S-K.
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