SEC Comment Letter for Coeur Mining, Inc. (CDE) (CIK 0000215466) (CDE) — Nov 23, 2016
Coeur Mining, Inc. (CDE) (CIK 0000215466)
Date: Nov. 23, 2016 · CIK: 0000215466 · Accession: 0000000000-16-102298
AI Filing Summary & Sentiment
Reasoning
Letter
Mail Stop 3561 November 23, 2016 Via Email Mr. Peter C. Mitchell Senior Vice President and Chief Financial Officer Coeur Mining, Inc. 104 S. Michigan Ave. Suite 900 Chicago IL 60603
Re: Coeur Mining, Inc. Form 10-Q for the quarter ended June 30, 2016 Response Dated November 4, 2016 File No. 1 -08641
Dear Mr. Mitchell:
We have reviewed your November 4, 2016 response to our comment letter 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 these comments within ten busine ss days by providing the requested information or advis e us as soon as possible when you will respond. If you do not believe our comments apply to your facts and circumstances , please tell us why in your response.
After reviewing your response to these comments, we may have additional comments. Unless we n ote otherwise, our references to prior comments are to comments in our October 25, 2016 letter.
Quarterly Report on Form 10 -Q for the Quarter ended June 30, 2016 Item 2. Management’s Discussion and Analysis of Financial Condition and Results of Operations Non-GAAP Financial Performance Measures, page 41
1. Your response to comment 3 and your proposed disclosure indicates that the tax impact of adjustments are generally determined based on statutory tax rates and the related jurisdictional tax attr ibutes, including the impact through the Company’s valuation allowance. However, your proposed disclosure does not clearly explain in any detail how the tax effect of the adjustment s for each period presented in your 10 -Q were determined. Please revise to clearly explain how the tax effect of your adjustments to net income to arrive at adjusted net income for each period presented were calculated or determined.
Mr. Peter C. Mitchell Coeur Mining, Inc. November 23 , 2016 Page 2
We remind you that the company and its management are responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the staff.
You may contact Linda Cvrkel, Staff Accountant at (202) 551 -3813 or me at (202) 551 - 3651 if you have questions regarding comments on the financial stat ements and related matters or for any other questions.
Sincerely,
/s/ Joel Parker
Show Raw Text
Mail Stop 3561 November 23, 2016 Via Email Mr. Peter C. Mitchell Senior Vice President and Chief Financial Officer Coeur Mining, Inc. 104 S. Michigan Ave. Suite 900 Chicago IL 60603 Re: Coeur Mining, Inc. Form 10-Q for the quarter ended June 30, 2016 Response Dated November 4, 2016 File No. 1 -08641 Dear Mr. Mitchell: We have reviewed your November 4, 2016 response to our comment letter 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 these comments within ten busine ss days by providing the requested information or advis e us as soon as possible when you will respond. If you do not believe our comments apply to your facts and circumstances , please tell us why in your response. After reviewing your response to these comments, we may have additional comments. Unless we n ote otherwise, our references to prior comments are to comments in our October 25, 2016 letter. Quarterly Report on Form 10 -Q for the Quarter ended June 30, 2016 Item 2. Management’s Discussion and Analysis of Financial Condition and Results of Operations Non-GAAP Financial Performance Measures, page 41 1. Your response to comment 3 and your proposed disclosure indicates that the tax impact of adjustments are generally determined based on statutory tax rates and the related jurisdictional tax attr ibutes, including the impact through the Company’s valuation allowance. However, your proposed disclosure does not clearly explain in any detail how the tax effect of the adjustment s for each period presented in your 10 -Q were determined. Please revise to clearly explain how the tax effect of your adjustments to net income to arrive at adjusted net income for each period presented were calculated or determined. Mr. Peter C. Mitchell Coeur Mining, Inc. November 23 , 2016 Page 2 We remind you that the company and its management are responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the staff. You may contact Linda Cvrkel, Staff Accountant at (202) 551 -3813 or me at (202) 551 - 3651 if you have questions regarding comments on the financial stat ements and related matters or for any other questions. Sincerely, /s/ Joel Parker Joel Parker Senior Assistant Chief Accountant Office of Beverages, Apparel and Mining