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SEC Comment Letter for UNITED STATES ANTIMONY CORP (UAMY) (CIK 0000101538) (UAMY) — Feb 27, 2013

UNITED STATES ANTIMONY CORP (UAMY) (CIK 0000101538)
Date: Feb. 27, 2013 · CIK: 0000101538 · Accession: 0000000000-13-010904

AI Filing Summary & Sentiment

Referenced dates: February 1, 2013

Date
February 27, 2013
Author
/s/ Pamela Howell
Form
UPLOAD
Company
UNITED STATES ANTIMONY CORP (UAMY) (CIK 0000101538)

Letter

February 27, 2013 Via E -mail Mr. John C. Lawrence Chief Executive Officer United States Antimony Corporation P.O. Box 643 Thompson Falls, MT 59873

Re: United States Antimony Corporation Amendment No. 1 to Form 10 -K for Fiscal Year Ended December 31, 2011 Filed January 8, 2013 Response submitted February 19, 2013 File No. 001 -08675

Dear Mr. Lawrence :

We have reviewed your filing an d supplemental response 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 within ten business days by providing the requested information or by advising us when you will provide the requested response. If you do not believe our comments apply to your facts and circumstances, please tell us why in your response.

After reviewing the information you provide in response to these comments, we may have addit ional comments.

Amendment No. 1 to Form 10 -K for Fiscal Year Ended December 31, 2011

Item 11. Executive Compensation, page 31

1. We note your response to comment five in our letter dated February 1, 2013 and we reissue the comment. We note that you made restricted stock awards to two executive officers in fiscal year 2011 according to the summary compensation table. Please provide us with draft tabular disclosure that you will include in a further amended Form 10 -K to provide the in formation required by Item 402(p) of Regulation S -K with respect to your outstanding and vested stock awards.

Summary Compensation Table, page 31

2. We note your response to comment six in our letter dated February 1, 2013 and we reissue the comment. The summary compensation table you provided in your draft

Mr. John C. Lawrence United States Antimony Corporation February 27, 2013 Page 2

disclosure is not in the format required by Item 402(n) of Regulation S -K. Please provide us with draft disclosure of a summary compensation table in the format required by Item 402(n) of Regulation S -K that you will include in a further amended Form 10 -K. In the summary compensation table you provide, please include footnote disclosure for the all other compensation as required by Item 402(n)(2)(ix) of Regulation S -K. In addition, the dollar amounts in the draft summary compensation table do not appear consistent with the prior summary compensation table, which reflected amounts in the all other payouts column. Please revise or advise.

Item 12. Security Ownership of Certain Beneficial Owners and Ma nagement, page 31

3. We reissue comment seven in our letter dated February 1, 2013. We note that you have provided separate disclosure for each separate class of securities. However, footnote four states that the Series A, C and D preferred shares carry vo ting rights. Please provide the disclosure pursuant to Item 403 of Regulation S -K regarding the voting class of securities. Please provide us with draft disclosure of the proposed revised table.

We urge all persons who are responsible for the accuracy and adequacy of the disclosure in the filing to be certain that the filing includes the information the Securities Exchange Act of 1934 and all applicable Exchange Act rules require. Since the compa ny and its management are in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy and adequacy of the disclosures they have made.

Please contact Tiffany Piland at (202) 551 -3589 or Pamela Howell at (202) 551 -3357 with any questions.

Sincerely,
/s/ Pamela Howell
for

Show Raw Text
February 27, 2013

Via E -mail
Mr. John C. Lawrence
Chief Executive Officer
United States Antimony Corporation
P.O. Box 643
Thompson Falls, MT 59873

Re: United States Antimony Corporation
 Amendment No. 1 to Form 10 -K for Fiscal Year Ended December 31, 2011
Filed January 8, 2013
Response submitted February 19, 2013
File No. 001 -08675

Dear Mr. Lawrence :

We have reviewed your filing an d supplemental response 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 within ten business days by providing the requested
information  or by advising us when you will provide the requested response.   If you do not
believe our comments apply to your facts and circumstances, please tell us why in your response.

After reviewing the information you provide in response to these  comments, we may
have  addit ional comments.

Amendment No. 1 to Form 10 -K for Fiscal Year Ended December 31, 2011

Item 11. Executive Compensation, page 31

1. We note your response to comment five  in our letter dated February 1, 2013 and we
reissue the comment.  We note that you made restricted stock awards to two executive
officers in fiscal year 2011 according to the summary compensation table.   Please provide
us with draft tabular disclosure that you will include in a further amended Form 10 -K to
provide the in formation required by Item 402(p) of Regulation S -K with respect to your
outstanding and vested stock awards.

Summary Compensation Table, page 31

2. We note your response to comment six  in our letter dated February 1, 2013 and we
reissue the comment.  The  summary compensation table you provided in your draft

Mr. John C. Lawrence
United States Antimony Corporation
February 27, 2013
Page 2

 disclosure is not in the format required by Item 402(n) of Regulation S -K.  Please provide
us with draft disclosure of a summary compensation table in the format required by Item
402(n) of Regulation S -K that you will include in a further amended Form 10 -K.  In the
summary compensation table you provide, please include footnote disclosure for the all
other compensation as required by Item 402(n)(2)(ix) of Regulation S -K.  In addition, the
dollar amounts  in the draft summary compensation table do not appear consistent with
the prior summary compensation table, which reflected amounts in the all other payouts
column.  Please revise or advise.

Item 12. Security Ownership of Certain Beneficial Owners and Ma nagement, page 31

3. We reissue comment seven in our letter dated February 1, 2013.  We note that you have
provided separate disclosure for each separate class of securities.  However, footnote four
states that the Series A, C and D preferred shares carry vo ting rights.  Please provide the
disclosure pursuant to Item 403 of Regulation S -K regarding the voting class of
securities.  Please provide us with draft disclosure of the proposed revised table.

We urge all persons who are responsible for the accuracy and adequacy of the disclosure
in the filing to be certain that the filing includes the information the Securities Exchange Act of
1934 and all applicable Exchange Act rules require.   Since the compa ny and its management are
in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy
and adequacy of the disclosures they have made.

 Please contact Tiffany Piland  at (202) 551 -3589 or Pamela Howell at (202) 551 -3357
with any questions.

Sincerely,

 /s/ Pamela Howell
 for

John Reynolds
Assistant Director