SEC Comment Letter for TOREADOR RESOURCES CORP (CIK 0000098720) — May 3, 2005
TOREADOR RESOURCES CORP (CIK 0000098720)
Date: May 3, 2005 · CIK: 0000098720 · Accession: 0000000000-05-021544
AI Filing Summary & Sentiment
Letter
April 19, 2005 via facsimile and U.S. mail Mr. Douglas Weir Senior Vice President, and Chief Financial Officer Toreador Resources Corporation 4809 Cole Avenue, Suite 108 Dallas, TX 75205
Re: Toreador Resources Corporation 10-K for the fiscal year ended December 31, 2004 File No. 0-02517
Dear Mr. Weir:
We have reviewed the above filing and have the following engineering comments. Our review has been limited to the specific issues identified in this letter. Where indicated, we think you should revise your document in response to these comments. If you disagree, we will consider your explanation as to why our comment is inapplicable or a revision is unnecessary. Please be as detailed as necessary in your explanation. After reviewing this information, we may or may not raise additional comments.
Please understand that the purpose of our review process is to assist you in your compliance with the applicable disclosure requirements and to enhance the overall disclosure in your filing. We look forward to working with you in these respects. We welcome any questions you may have about our comments or on any other aspect of our review. Feel free to call us at the telephone numbers listed at the end of this letter.
10-K for the fiscal year ended December 31, 2004
filed on March 31, 2005
Properties, page 19
Title to Oil and Natural Gas Properties, page 21
1. You disclose that 69% of your proved reserves in France and 31% of your proved reserves in Turkey will not be produced until after the exploitation permits have expired. These post-expiration volumes represent almost 60% of your total proved reserves. As we indicate on our website at: http://www.sec.gov/divisions/corpfin/guidance/cfactfaq.htm it is the staff`s position that automatic renewal of such agreements cannot be expected if the regulatory body has the authority to end the agreement unless there is a long and clear track record which supports the conclusion that such approvals and renewals are a matter of course. Please revise your document to remove these reserves from the classification of proved reserves until such time that the contracts have been legally renewed.
Supplemental Oil and Natural Gas Reserves and Standardized Measure Information (Unaudited), page F-32
2. We note the large positive revision of oil reserves in France in 2002 and we also note that your oil production rate in France has not significantly changed since 2002. Your reserve life in France is currently over 27 years. Supplementally, please provide us with the technical justification for these reserves and the reason that they were increased in 2002. In addition, please tell us of your plans for increasing production of these reserves and for developing the remaining proved undeveloped reserves.
Closing Comments
As appropriate, please amend your filings in response to these comments within 10 business days. You may also wish to provide us with marked copies of any amendment to expedite our review. Please furnish a cover letter with your amendment that keys your responses to our comments and provides any requested supplemental information. Detailed cover letters greatly facilitate our review. File your responses on EDGAR. Please understand that we may have additional comments after reviewing your amendment and responses to our comments.
Direct questions related to engineering issues to James Murphy, Petroleum Engineer, at (202) 942-2939. Direct questions related to all other disclosure issues to the undersigned at (202) 942-1870. Direct all correspondence to the following ZIP code: 20549-0405.
Sincerely,
H. Roger Schwall
Assistant Director
Show Raw Text
<DOCUMENT>
<TYPE>LETTER
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<TEXT>
April 19, 2005
via facsimile and U.S. mail
Mr. Douglas Weir
Senior Vice President, and Chief Financial Officer
Toreador Resources Corporation
4809 Cole Avenue, Suite 108
Dallas, TX 75205
Re: Toreador Resources Corporation
10-K for the fiscal year ended December 31, 2004
File No. 0-02517
Dear Mr. Weir:
We have reviewed the above filing and have the following
engineering comments. Our review has been limited to the specific
issues identified in this letter. Where indicated, we think you
should revise your document in response to these comments. If you
disagree, we will consider your explanation as to why our comment
is
inapplicable or a revision is unnecessary. Please be as detailed
as
necessary in your explanation. After reviewing this information,
we
may or may not raise additional comments.
Please understand that the purpose of our review process is
to
assist you in your compliance with the applicable disclosure
requirements and to enhance the overall disclosure in your filing.
We look forward to working with you in these respects. We welcome
any questions you may have about our comments or on any other
aspect
of our review. Feel free to call us at the telephone numbers
listed
at the end of this letter.
10-K for the fiscal year ended December 31, 2004
filed on March 31, 2005
Properties, page 19
Title to Oil and Natural Gas Properties, page 21
1. You disclose that 69% of your proved reserves in France and 31%
of
your proved reserves in Turkey will not be produced until after
the
exploitation permits have expired. These post-expiration volumes
represent almost 60% of your total proved reserves. As we
indicate
on our website at:
http://www.sec.gov/divisions/corpfin/guidance/cfactfaq.htm it is
the
staff`s position that automatic renewal of such agreements cannot
be
expected if the regulatory body has the authority to end the
agreement unless there is a long and clear track record which
supports the conclusion that such approvals and renewals are a
matter
of course. Please revise your document to remove these reserves
from
the classification of proved reserves until such time that the
contracts have been legally renewed.
Supplemental Oil and Natural Gas Reserves and Standardized Measure
Information (Unaudited), page F-32
2. We note the large positive revision of oil reserves in France
in
2002 and we also note that your oil production rate in France has
not
significantly changed since 2002. Your reserve life in France is
currently over 27 years. Supplementally, please provide us with
the
technical justification for these reserves and the reason that
they
were increased in 2002. In addition, please tell us of your plans
for increasing production of these reserves and for developing the
remaining proved undeveloped reserves.
Closing Comments
As appropriate, please amend your filings in response to
these
comments within 10 business days. You may also wish to provide us
with marked copies of any amendment to expedite our review.
Please
furnish a cover letter with your amendment that keys your
responses
to our comments and provides any requested supplemental
information.
Detailed cover letters greatly facilitate our review. File your
responses on EDGAR. Please understand that we may have additional
comments after reviewing your amendment and responses to our
comments.
Direct questions related to engineering issues to James
Murphy,
Petroleum Engineer, at (202) 942-2939. Direct questions related
to
all other disclosure issues to the undersigned at (202) 942-1870.
Direct all correspondence to the following ZIP code: 20549-0405.
Sincerely,
H. Roger Schwall
Assistant Director
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Mr. Douglas Weir
Toreador Resources Corporation
April 19, 2005
Page 1
UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-0405
DIVISION OF
CORPORATION FINANCE
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