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SEC Comment Letter for Coeur Mining, Inc. (CDE) (CIK 0000215466) (CDE) — Dec 11, 2014

Coeur Mining, Inc. (CDE) (CIK 0000215466)
Date: Dec. 11, 2014 · CIK: 0000215466 · Accession: 0000000000-14-064302

Financial Reporting Risk Disclosure Internal Controls

AI Filing Summary & Sentiment

Sentiment
Urgency
Document Type
Confidence
SEC Posture
Company Posture

Summary

Reasoning

Date
December 31, 2013
Author
/s/Tia L. Jenkins
Form
UPLOAD
Company
Coeur Mining, Inc. (CDE) (CIK 0000215466)

Letter

December 11 , 2014 Via E -mail Mr. Mitchell J. Krebs Chief Executive Officer Coeur Mining, Inc. 104 S. Michigan Avenue, Suite 900 Chicago, IL 60603

Re: Coeur Mining, Inc. Form 10 -K for the Year Ended December 31, 2013 Filed February 26, 2014 Response dated November 19, 2014 File No. 001 -08641

Dear Mr. Krebs :

We have reviewed your response 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 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 provid e in response to these comments, we may have additional comments.

Form 10 -K for the Year Ended December 31, 2013

General

1. We note your response to comments 4 and 5 stating your newly -designated royalty segment asset values and revenues are limited in nature, and you believe your property descriptions and consolidated royalty revenue disclosures are appropriate when compared to your total mining operations. In addition , you state that the absence of production results, which form the basis for your roya lty revenues, is appropriate when compared to your total revenues. In future filings, if true, please clearly state your royalty segment assets and revenues are not material to your company.

Mr. Mitchell J. Krebs Coeur Mining , Inc. December 11 , 2014 Page 2

Form 10 -Q for the Quarter Ended June 30, 2014

Management’s Discussion and Analysis of Financial Condition and Results of Operations Highlights – Three months Ended June 30, 2014, page 31

2. We note from your response to our prior comment 7 that you did not consider the results of the La Preciosa feasibility study to be a triggering event for the purpose of assessing impairment at June 30, 2014. We also note from disclosures in your Form 8-K filed on July 30, 2014 that :

 the 201 4 Feasibility Study reported a decrease in the after - tax NPV, estimated ini tial mine life, silver/gold recovery rate and total silver/gold production compared to your July 2013 Preliminary Economic Assessment;

 the after- tax NPV calculat ed in your Feasibility Study appears to be below the carrying value of your La Preciosa asset s; and

 since your acquisition of La Preciosa, precious metal s prices have decreased and Mexico has increased the taxes on precious metals mines.

Please tell us how you considered these findings and developments in your evaluation of the triggering events for purpose of assessing impairment at June 30, 2014. Provide us your analysis explaining the factors considered including any mitigating factors and the basis for your conclusion. Refer to FASB ASC 360 -10-35-21, 35 -21(b) and 35-21(c) for further guidan ce.

You may contact James Giugliano at (202) 551 -3319, or Raj Rajan at (202) 551 -3388, if you have questions regarding comments on the financial statements and related matters. You may contact George Schuler, Mining Engineer, at (202) 551 -3718 with que stions about engineering comments.

Sincerely,
/s/Tia L. Jenkins

Show Raw Text
December 11 , 2014

Via E -mail
Mr. Mitchell J.  Krebs
Chief Executive Officer
Coeur Mining, Inc.
104 S. Michigan Avenue, Suite 900
Chicago, IL 60603

 Re: Coeur Mining, Inc.
  Form 10 -K for the Year Ended December 31, 2013
  Filed February 26, 2014
  Response dated November 19, 2014
  File No. 001 -08641

Dear Mr. Krebs :

We have reviewed your response 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 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 provid e in response to these comments, we may
have additional comments.

Form 10 -K for the  Year Ended December 31, 2013

General

1. We note your response to comments 4 and 5 stating your newly -designated royalty
segment asset values and revenues are limited in nature, and you believe your
property descriptions and consolidated royalty revenue disclosures are appropriate
when compared to your total mining operations.  In addition , you state that the
absence of production results, which form the basis for your roya lty revenues, is
appropriate when compared to your total revenues.  In future filings, if true, please
clearly state your royalty segment assets and revenues are not material to your
company.

Mr. Mitchell J.  Krebs
Coeur Mining , Inc.
December 11 , 2014
Page 2

 Form 10 -Q for the Quarter Ended June 30, 2014

Management’s Discussion and Analysis of Financial Condition and Results of Operations
Highlights – Three months Ended June 30, 2014, page 31

2. We note from your response to our prior comment 7 that you did not consider the
results of the La Preciosa  feasibility study to be a triggering event for the purpose of
assessing impairment at June 30, 2014.   We also note from disclosures in your Form
8-K filed on July 30, 2014 that :

 the 201 4 Feasibility Study reported a decrease in the after - tax NPV, estimated ini tial
mine life, silver/gold recovery rate and   total silver/gold production compared to your
July 2013 Preliminary Economic Assessment;

 the after- tax NPV calculat ed in your Feasibility Study appears to be below the
carrying value of your La Preciosa asset s; and

 since your acquisition of La Preciosa, precious metal s prices have decreased and
Mexico has increased the taxes on precious metals mines.

Please tell us how you considered these findings and developments in your  evaluation of
the triggering events  for purpose of assessing impairment at June 30, 2014.  Provide us
your analysis explaining the factors considered including any mitigating factors and the
basis for your conclusion.   Refer to FASB ASC 360 -10-35-21, 35 -21(b) and 35-21(c) for
further guidan ce.

 You may contact James Giugliano at (202) 551 -3319, or Raj Rajan at (202) 551 -3388, if
you have questions regarding comments on the financial statements and related matters.  You
may contact George Schuler, Mining Engineer, at (202) 551 -3718 with que stions about
engineering comments.

        Sincerely,

        /s/Tia L. Jenkins

        Tia L. Jenkins
        Senior Assistant Chief Accountant
Office of Beverages, Apparel, and
Mining