SEC Comment Letter for AgEagle Aerial Systems Inc. (UAVS) (CIK 0000008504) (UAVS) — Jul 11, 2016
AgEagle Aerial Systems Inc. (UAVS) (CIK 0000008504)
Date: July 11, 2016 · CIK: 0000008504 · Accession: 0000000000-16-083843
AI Filing Summary & Sentiment
Reasoning
Letter
Mail Stop 4628 July 11 , 2016 Via E -Mail Robert G. Watson Jr. Chief Executive Officer Enerjex Resources, Inc. 4040 Broadway, Suite 508 San Antonio, TX 78209
Re: Enerjex Resources, Inc. Form 10-K for the Fiscal Year ended December 31, 2014 Filed March 31, 2015 Form 10 -K for the Fiscal Year ended December 31, 2015 Filed April 11, 2016 File No. 1 -36492
Dear Mr. Watson :
We have reviewed your filings and response letter and have the following comment s. In some of our comments , we may ask you to provide us with information so we may better understand your disclosure.
Please respond to these comments within ten busine ss days by providing the requested information or advis e us as soon as possible when you will respond. If you do not believe our comments apply to your facts and circumstances, please tell us why in your response.
After reviewing any amendment to your filing and the information you provide in response to these comments , we may have additional comments. Unless we note otherwise, our references to prior comments are to comment s in our May 11 , 2016 letter.
Form 10 -K for the Fiscal Year ended December 31, 2014
Notes to Consolidated Financial Statements
Supplemental Oil and Gas Reserve Information (Unaudited), page F -18
Estimated Quantities of Proved Reserves, page F -19
1. We have read you r response to prior comment one, including your proposed disclosure regarding the beginning and end -of-year quantities for each product type of proved developed and proved undeveloped reserves. We note that while FASB ASC 932 -235-
Robert G. Watson, Jr. Enerjex Resources, Inc. July 11, 2016 Page 2
50-5 requires that you quantify various types of changes in total p roved reserves for each period, you have elected in your latest submission to also include these details for each product category (which is not a requirement).
We also note that while you have presented details for two categories of proved developed re serves, based on whether the properties are producing or not producing (which is also not a requirement), you have not included totals for proved developed reserves, and therefore this presentation does not include all of the information required by FASB A SC 932 -235-50-4. Further revisions will be necessary to include total proved developed reserves at the beginning and end of each period.
We suggest that you follow the guidance in Example 1 of FASB ASC 932 -235-55-2 in organizing the informatio n that is required to be disclosed for proved reserves.
Form 10 -K for the Fiscal Year ended December 31, 2015
Notes to Consolidated Financial Statements
Supplemental Oil and Gas Reserve Information (Unaudited), page F -17
Estimated Quantities of Proved Reserves, page F -18
2. We note your response to prior comment two does not include the information we had requested concerning your plans for developing proved reserves. Please describe any limitations on your ability to provide such information, as would ordinarily be necessary to establish or demonstrate compliance with the proved reserve definitions in Rule 4 - 10(a) of Regulation S -X. We reissue prior comment two.
You may contact John Hodgin, Petroleum Engineer, at (202) 551 -3699 if you have questions regarding the comments. Please contact Karl Hiller, Branch Chief, at (202) 551 -3686 with any other questions.
Sincerely,
/s/ Karl Hiller for
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Mail Stop 4628 July 11 , 2016 Via E -Mail Robert G. Watson Jr. Chief Executive Officer Enerjex Resources, Inc. 4040 Broadway, Suite 508 San Antonio, TX 78209 Re: Enerjex Resources, Inc. Form 10-K for the Fiscal Year ended December 31, 2014 Filed March 31, 2015 Form 10 -K for the Fiscal Year ended December 31, 2015 Filed April 11, 2016 File No. 1 -36492 Dear Mr. Watson : We have reviewed your filings and response letter and have the following comment s. In some of our comments , we may ask you to provide us with information so we may better understand your disclosure. Please respond to these comments within ten busine ss days by providing the requested information or advis e us as soon as possible when you will respond. If you do not believe our comments apply to your facts and circumstances, please tell us why in your response. After reviewing any amendment to your filing and the information you provide in response to these comments , we may have additional comments. Unless we note otherwise, our references to prior comments are to comment s in our May 11 , 2016 letter. Form 10 -K for the Fiscal Year ended December 31, 2014 Notes to Consolidated Financial Statements Supplemental Oil and Gas Reserve Information (Unaudited), page F -18 Estimated Quantities of Proved Reserves, page F -19 1. We have read you r response to prior comment one, including your proposed disclosure regarding the beginning and end -of-year quantities for each product type of proved developed and proved undeveloped reserves. We note that while FASB ASC 932 -235- Robert G. Watson, Jr. Enerjex Resources, Inc. July 11, 2016 Page 2 50-5 requires that you quantify various types of changes in total p roved reserves for each period, you have elected in your latest submission to also include these details for each product category (which is not a requirement). We also note that while you have presented details for two categories of proved developed re serves, based on whether the properties are producing or not producing (which is also not a requirement), you have not included totals for proved developed reserves, and therefore this presentation does not include all of the information required by FASB A SC 932 -235-50-4. Further revisions will be necessary to include total proved developed reserves at the beginning and end of each period. We suggest that you follow the guidance in Example 1 of FASB ASC 932 -235-55-2 in organizing the informatio n that is required to be disclosed for proved reserves. Form 10 -K for the Fiscal Year ended December 31, 2015 Notes to Consolidated Financial Statements Supplemental Oil and Gas Reserve Information (Unaudited), page F -17 Estimated Quantities of Proved Reserves, page F -18 2. We note your response to prior comment two does not include the information we had requested concerning your plans for developing proved reserves. Please describe any limitations on your ability to provide such information, as would ordinarily be necessary to establish or demonstrate compliance with the proved reserve definitions in Rule 4 - 10(a) of Regulation S -X. We reissue prior comment two. You may contact John Hodgin, Petroleum Engineer, at (202) 551 -3699 if you have questions regarding the comments. Please contact Karl Hiller, Branch Chief, at (202) 551 -3686 with any other questions. Sincerely, /s/ Karl Hiller for H. Roger Schwall Assistant Director Office of Natural Resources