SEC Comment Letter for Coeur Mining, (CDE) — Aug 5, 2025
Coeur Mining, Inc.
Date: Aug. 5, 2025 · CIK: 0000215466 · Accession: 0000000000-25-008205
AI Filing Summary & Sentiment
File numbers found in text: 001-08641
Letter
August 5, 2025 Thomas S. Whelan Chief Financial Officer Coeur Mining, Inc. 200 South Wacker Drive, Suite 2100 Chicago, Illinois 60606 Re:Coeur Mining, Inc. Form 10-Q for the Fiscal Quarter Ended March 31, 2025 Form 10-K for the Fiscal Year Ended December 31, 2024 Response dated July 11, 2025 File No. 001-08641 Dear Thomas S. Whelan: We have reviewed your July 11, 2025 response to our comment letter and have the following comments. Please respond to this letter within ten business days by providing the requested information or advise us as soon as possible when you will respond. If you do not believe a comment applies to your facts and circumstances, please tell us why in your response. After reviewing your response to this letter, we may have additional comments. Unless we note otherwise, any references to prior comments are to comments in our June 26, 2025 letter Response dated July 11, 2025 Form 10-Q for the Fiscal Quarter Ended March 31, 2025 Non-GAAP Financial Performance Measures, page 38 1.We note your response to prior comment 1 regarding the adjustment for “Acquired inventory purchase price.” However, we do not agree that this adjustment is appropriate within the context of Question 100.04 of the Compliance and Disclosure Interpretations on Non-GAAP Financial Measures. Please revise your presentation to remove this purchase accounting adjustment from your Adjusted net income (loss) and Adjusted EBITDA measures.
August 5, 2025 Page 2 Form 10-K for the Fiscal Year Ended December 31, 2024 Item 7. Management's Discussion and Analysis of Financial Condition and Results of Operations Non-GAAP Financial Performance Measures, page 57 2.We note your response to prior comment 2 regarding inventory adjustments. Please reconcile the inventory adjustment amounts for the Rochester mine in the table of your response on page 4 to the inventory adjustments excluded from Adjusted costs applicable to sales. For example, we note the inventory adjustment for 2023 of $(104) in your response does not agree with the adjustment in the 2024 earnings release of $(17,305). For 2022, we note the adjustment of $1,273 in your response is not equal to the amount disclosed in the 2023 earnings release of $(9,232). 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. Please contact Ranjit Singh Pawar at 202-551-2702 or Jennifer O'Brien at 202-551- 3721 if you have questions regarding comments on the financial statements and related matters. Sincerely, Division of Corporation Finance Office of Energy & Transportation
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August 5, 2025
Thomas S. Whelan
Chief Financial Officer
Coeur Mining, Inc.
200 South Wacker Drive, Suite 2100
Chicago, Illinois 60606
Re:Coeur Mining, Inc.
Form 10-Q for the Fiscal Quarter Ended March 31, 2025
Form 10-K for the Fiscal Year Ended December 31, 2024
Response dated July 11, 2025
File No. 001-08641
Dear Thomas S. Whelan:
We have reviewed your July 11, 2025 response to our comment letter and have
the following comments.
Please respond to this letter within ten business days by providing the requested
information or advise us as soon as possible when you will respond. If you do not believe a
comment applies to your facts and circumstances, please tell us why in your response.
After reviewing your response to this letter, we may have additional comments.
Unless we note otherwise, any references to prior comments are to comments in our
June 26, 2025 letter
Response dated July 11, 2025
Form 10-Q for the Fiscal Quarter Ended March 31, 2025
Non-GAAP Financial Performance Measures, page 38
1.We note your response to prior comment 1 regarding the adjustment for “Acquired
inventory purchase price.” However, we do not agree that this adjustment is
appropriate within the context of Question 100.04 of the Compliance and Disclosure
Interpretations on Non-GAAP Financial Measures. Please revise your presentation to
remove this purchase accounting adjustment from your Adjusted net income (loss)
and Adjusted EBITDA measures.
August 5, 2025
Page 2
Form 10-K for the Fiscal Year Ended December 31, 2024
Item 7. Management's Discussion and Analysis of Financial Condition and Results of
Operations
Non-GAAP Financial Performance Measures, page 57
2.We note your response to prior comment 2 regarding inventory adjustments. Please
reconcile the inventory adjustment amounts for the Rochester mine in the table of
your response on page 4 to the inventory adjustments excluded from Adjusted costs
applicable to sales. For example, we note the inventory adjustment for 2023 of $(104)
in your response does not agree with the adjustment in the 2024 earnings release of
$(17,305). For 2022, we note the adjustment of $1,273 in your response is not equal to
the amount disclosed in the 2023 earnings release of $(9,232).
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.
Please contact Ranjit Singh Pawar at 202-551-2702 or Jennifer O'Brien at 202-551-
3721 if you have questions regarding comments on the financial statements and related
matters.
Sincerely,
Division of Corporation Finance
Office of Energy & Transportation