SEC Comment Letter 0000000000-24-010340 to ROYAL GOLD INC (RGLD) (CIK 0000085535) (RGLD)
ROYAL GOLD INC (RGLD) (CIK 0000085535)
Date: Sept. 13, 2024 · CIK: 0000085535 · Accession: 0000000000-24-010340
AI Filing Summary & Sentiment
File numbers found in text: 001-13357
Letter
September 13, 2024 William Heissenbuttel President and Chief Executive Officer Royal Gold, Inc. 1144 15th Street, Suite 2500 Denver, CO 80202 Re:Royal Gold, Inc. Form 10-K for the Fiscal Year Ended December 31, 2023 Form 10-K/A for the Fiscal Year Ended December 31, 2023 File No. 001-13357 Dear William Heissenbuttel: We have reviewed your June 14, 2024 response to our comment letter and have the following comment. Please respond to this letter within ten business days by providing the requested information or advise us as soon as possible when you will respond. If you do not believe a comment applies to your facts and circumstances, please tell us why in your response. After reviewing your response to this letter, we may have additional comments. Unless we note otherwise, any references to prior comments are to comments in our May 22, 2024 letter. Form 10-K/A for the Fiscal Year Ended December 31, 2023 Item 2. Properties, page 4 1.We note your response to comment 1 and do not agree that a separate section of supplemental disclosure of resources and reserves prepared under reporting regimes other than S-K 1300 would be appropriate to include in your Form 10-K filing, and we do not concur that the proposed supplemental disclosure is consistent with the royalty accommodations under Items 1303(a)(3) and 1304(a)(2) of Regulation S-K. Please file an amended Form 10-K filing that excludes mineral resources and mineral reserves that are not compliant with S-K 1300.
September 13, 2024 Page 2 Please contact Paul Cline at 202-551-3851 or Jennifer Monick at 202-551-3295 if you have questions regarding comments on the financial statements and related matters. If you have questions regarding comments on mining operations, please contact John Coleman at 202-551- 3610 or Craig Arakawa at 202-551-3650. Sincerely, Division of Corporation Finance Office of Real Estate & Construction
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September 13, 2024
William Heissenbuttel
President and Chief Executive Officer
Royal Gold, Inc.
1144 15th Street, Suite 2500
Denver, CO 80202
Re:Royal Gold, Inc.
Form 10-K for the Fiscal Year Ended December 31, 2023
Form 10-K/A for the Fiscal Year Ended December 31, 2023
File No. 001-13357
Dear William Heissenbuttel:
We have reviewed your June 14, 2024 response to our comment letter and have the
following comment.
Please respond to this letter within ten business days by providing the requested
information or advise us as soon as possible when you will respond. If you do not believe a
comment applies to your facts and circumstances, please tell us why in your response.
After reviewing your response to this letter, we may have additional comments. Unless we
note otherwise, any references to prior comments are to comments in our May 22, 2024 letter.
Form 10-K/A for the Fiscal Year Ended December 31, 2023
Item 2. Properties, page 4
1.We note your response to comment 1 and do not agree that a separate section of
supplemental disclosure of resources and reserves prepared under reporting regimes other
than S-K 1300 would be appropriate to include in your Form 10-K filing, and we do not
concur that the proposed supplemental disclosure is consistent with the royalty
accommodations under Items 1303(a)(3) and 1304(a)(2) of Regulation S-K. Please file an
amended Form 10-K filing that excludes mineral resources and mineral reserves that are
not compliant with S-K 1300.
September 13, 2024
Page 2
Please contact Paul Cline at 202-551-3851 or Jennifer Monick at 202-551-3295 if you
have questions regarding comments on the financial statements and related matters. If you have
questions regarding comments on mining operations, please contact John Coleman at 202-551-
3610 or Craig Arakawa at 202-551-3650.
Sincerely,
Division of Corporation Finance
Office of Real Estate & Construction