SEC Comment Letter for Coeur Mining, Inc. (CDE) (CIK 0000215466) (CDE) — Jun 20, 2006
Coeur Mining, Inc. (CDE) (CIK 0000215466)
Date: June 20, 2006 · CIK: 0000215466 · Accession: 0000000000-06-028898
AI Filing Summary & Sentiment
Reasoning
Referenced dates: May 22, 2006
Letter
UNITED STATES SECURITIES AND EXCHANGE COMMISSION 100 F Street, NE WASHINGTON, D.C. 20549-7010 DIVISION OF CORPORATION FINANCE MAIL STOP 7010 June 20, 2006 Mr. James A. Sabala Chief Financial Officer Coeur d’Alene Mines Corporation 505 Front Ave., P.O. Box “I” Coeur d’Alene, ID 83816
Re: Coeur d’Alene Mines Corporation Form 10-K for Fiscal Year Ended December 31, 2005 Filed March 14, 2006 Form 10-Q for Fiscal Quarter Ended March 31, 2006 Filed May 9, 2006 Response letter dated May 22, 2006 File No. 1-08641
Dear Mr. Sabala:
We have reviewed your filings and response letter and have the following comments. We have limited our review of your filings to those issues we have addressed in our comments. 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. In some of our comments, we may ask you to provide us with information so we may better understand your disclosure. After reviewing this information, we may raise additional comments.
Form 10-Q for the Fiscal Quarter Ended March 31, 2006
Controls and Procedures, page 43
1. We note that you designed your disclosure controls and procedures to provide “reasonable assurance” of achieving the desired control objectives. In future filings, please revise your conclusion to indicate, if true, that your disclosure controls and procedures are effective at the “reasonable assurance” level. We note that your disclosure in your Form 10-K for the fiscal year ended December 31, 2005 indicated that your disclosure controls and procedures were effective at the reasonable assurance level.
Mr. James A. Sabala Coeur d’Alene Mines Corporation June 20, 2006 Page 2
Engineering Comments
Form 10-K for the Fiscal Year Ended December 31, 2005
Silver and Gold Mining Properties, page 3
2. Revise your disclosure to include sufficient information in reserve tables for investors to figure the amount of minable reserves from the “in place” amounts that you disclose. In most cases, this means including a footnote in each reserve table of the weighted average mining recover, if it does not already have that.
Australia - Endeavor Mine, page 12 and Australia – Broken Hill Mine, page 14
3. Your supplemental information indicates that the maximum amount of payable ounces of silver you have acquired at the Endeavor Mine exceeds the mine’s reserve estimates at this time. Please disclose this information. To the extent this condition also applies to the Broken Hill Mine, disclose that information.
Alaska – Kensington Gold Project, page 18
4. We note a significant change in your estimated capital costs for the Kensington project between your 2004 and 2005 Form 10-K filing. In the latest filing, expand your disclosure about the reasons for this increase in capital costs, and compare the two estimates.
Closing Comments
As appropriate, please amend your filing and respond to these comments within 10 business days or tell us when you will provide us with a response. You may wish to provide us with marked copies of the amendment to expedite our review. Please furnish a cover letter with your amendment that keys your responses to our comments and provides any requested information. Detailed cover letters greatly facilitate our review. Please understand that we may have additional comments after reviewing your amendment and responses to our comments.
You may contact Jennifer Goeken at (202) 551-3721, Kevin Stertzel at (202) 551- 3723 or Jill Davis, Branch Chief, at (202) 551-3683 if you have questions regarding comments on the financial statements and related matters. You may contact Roger Baer, Mining Engineer, at (202) 551-3705 with questions about engineering comments. Please contact me at (202) 551-3740 with any other questions.
S i n c e r e l y ,
Mr. James A. Sabala Coeur d’Alene Mines Corporation June 20, 2006 Page 3
H . R o g e r S c h w a l l A s s i s t a n t D i r e c t o r
Show Raw Text
UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
100 F Street, NE
WASHINGTON, D.C. 20549-7010
DIVISION OF
CORPORATION FINANCE MAIL STOP 7010
June 20, 2006
Mr. James A. Sabala
Chief Financial Officer
Coeur d’Alene Mines Corporation
505 Front Ave., P.O. Box “I”
Coeur d’Alene, ID 83816
Re: Coeur d’Alene Mines Corporation
Form 10-K for Fiscal Year Ended December 31, 2005
Filed March 14, 2006
Form 10-Q for Fiscal Quarter Ended March 31, 2006
Filed May 9, 2006
Response letter dated May 22, 2006
File No. 1-08641
Dear Mr. Sabala:
We have reviewed your filings and response letter and have the following
comments. We have limited our review of your filings to those issues we have addressed
in our comments. 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. In some of our comments, we may ask you to provide us with information so we may better understand your disclosure. After reviewing this information, we may raise additional comments.
Form 10-Q for the Fiscal Quarter Ended March 31, 2006
Controls and Procedures, page 43
1. We note that you designed your disclosure controls and procedures to provide “reasonable assurance” of achieving the desired control objectives. In future filings, please revise your conclusion to indicate, if true, that your disclosure controls and procedures are effective at the “reasonable assurance” level. We note that your disclosure in your Form 10-K for the fiscal year ended December 31, 2005 indicated that your disclosure controls and procedures were effective at the reasonable assurance level.
Mr. James A. Sabala
Coeur d’Alene Mines Corporation
June 20, 2006 Page 2
Engineering Comments
Form 10-K for the Fiscal Year Ended December 31, 2005
Silver and Gold Mining Properties, page 3
2. Revise your disclosure to include sufficient information in reserve tables for investors to figure the amount of minable reserves from the “in place” amounts that you disclose. In most cases, this means including a footnote in each reserve table of the weighted average mining recover, if it does not already have that.
Australia - Endeavor Mine, page 12 and Australia – Broken Hill Mine, page 14
3. Your supplemental information indicates that the maximum amount of payable ounces of silver you have acquired at the Endeavor Mine exceeds the mine’s reserve estimates at this time. Please disclose this information. To the extent this condition also applies to the Broken Hill Mine, disclose that information.
Alaska – Kensington Gold Project, page 18
4. We note a significant change in your estimated capital costs for the Kensington project between your 2004 and 2005 Form 10-K filing. In the latest filing, expand your disclosure about the reasons for this increase in capital costs, and compare the two estimates.
Closing Comments
As appropriate, please amend your filing and respond to these comments within
10 business days or tell us when you will provide us with a response. You may wish to provide us with marked copies of the amendment to expedite our review. Please furnish a cover letter with your amendment that keys your responses to our comments and provides any requested information. Detailed cover letters greatly facilitate our review. Please understand that we may have additional comments after reviewing your amendment and responses to our comments.
You may contact Jennifer Goeken at (202) 551-3721, Kevin Stertzel at (202) 551-
3723 or Jill Davis, Branch Chief, at (202) 551-3683 if you have questions regarding comments on the financial statements and related matters. You may contact Roger Baer, Mining Engineer, at (202) 551-3705 with questions about engineering comments. Please contact me at (202) 551-3740 with any other questions.
S i n c e r e l y ,
Mr. James A. Sabala
Coeur d’Alene Mines Corporation
June 20, 2006 Page 3
H . R o g e r S c h w a l l
A s s i s t a n t D i r e c t o r