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
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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