SEC Company Response from Coeur Mining, Inc. (CDE) (CIK 0000215466) (CDE) — Nov 19, 2014
Coeur Mining, Inc. (CDE) (CIK 0000215466)
Date: Nov. 19, 2014 · CIK: 0000215466 · Accession: 0000215466-14-000104
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 001-08641
Letter
VIA EDGAR AND HAND DELIVERY Office of Beverages, Apparel, and Mining Division of Corporation Finance Coeur Mining, Inc. Form 10-K for the Year Ended December 31, 2013 Filed February 26, 2014 File No. 001-08641
Dear Ms. Jenkins:
On behalf of Coeur Mining, Inc. (the “Company”), this letter responds to your letter, dated November 6, 2014 (the “Comment Letter”), regarding the above-referenced Annual Report on Form 10‑K for the year ended December 31, 2013 (the “Annual Report”), filed with the Securities and Exchange Commission (the “Commission”) on February 26, 2014. Each comment of the Staff of the Division of Corporation Finance of the Commission (the “Staff”) is set forth below, followed by the corresponding response. For ease of reference, the headings and numbered paragraphs below correspond to the headings and numbered comments in the Comment Letter. Each response of the Company is set forth in ordinary type beneath the corresponding comment of the Staff appearing in bold type.
Form 10-K for the Year Ended December 31, 2013
Management’s Discussion and Analysis of Financial Condition and Results of Operations, page 31
Critical Accounting Policies and Developments - Impairments, page 33
1.
We note your disclosure under Note 4 that you recorded an impairment charge of $773 million to mining properties in 2013. Considering your impairment charges and significant decline in your realized silver and gold prices during the periods reported, to enhance investor’s understanding regarding your recent impairment testing of long lived assets, please confirm that you will disclose the following in future filings:
Coeur Mining, Inc. | 104 S. Michigan Ave., Suite 900 | Chicago, Illinois 60603 | t: 312-489-5843 | f: 312-489-5897 | www.coeur.com
•
the amount of long-lived assets (mineral interests and property, plant and equipment) allocated to each of the asset groups that are at risk of impairment and the percentage by which fair value exceeded carrying value as of the date of the most recent test;
•
a description of the methods and key assumptions used and how the key assumptions were determined;
•
a discussion of the degree of uncertainty associated with the key assumptions in as specific a manner as practicable;
•
the factors that affect variability in the pricing assumptions; and,
•
a description of potential events and/or changes in circumstances that could reasonably be expected to negatively affect the key assumptions.
Please provide us with a draft of your proposed disclosures. Refer to FR-72, which can be found on our website at: http://www.sec.gov/rules/interp/33-8350.htm.
At December 31, 2013, the Company identified impairment triggering events at its Palmarejo and Kensington mines. The triggering events identified were sustained and continued operating losses combined with results of the revised life-of-mine plans for those two mines. The Company did not identify any additional triggering events nor has the Company recorded any goodwill associated with its mining properties or other assets, and therefore, in accordance with FASB ASC 360, the Company did not conduct further impairment testing. The Company confirms it will enhance its Critical Accounting Policies and Developments - Impairments discussion in future filings to include more specific detail related to key assumptions used in impairment testing and related risk and uncertainties associated with those key assumptions. An example of the disclosure that would have been included in the Annual Report is as follows:
Impairments
We review and evaluate our long-lived assets for impairment when events or changes in circumstances indicate that the related carrying amounts may not be recoverable. Asset impairment is considered to exist if the total estimated undiscounted pre-tax future cash flows are less than the carrying amount of the asset. In estimating future cash flows, assets are grouped at the lowest level for which there is identifiable cash flows that are largely independent of future cash flows from other asset groups. An impairment loss is measured and recorded based on discounted estimated future cash flows. Future cash flows are estimated based on estimated quantities of recoverable minerals, expected silver and gold prices (considering current and historical prices, trends and related factors), production levels, operating costs, capital requirements and reclamation costs, all based on life-of-mine plans. The significant assumptions used in determining future cash flows for each mine site asset group at December 31, 2013, apart from production cost and capitalized expenditure assumptions unique to each operation, included long-term silver and gold prices of $25 and $1,450 per ounce (consistent with the Company’s long-term reserve prices), respectively, a U.S. to Mexican Peso long-term exchange rate of 12.5, a U.S. to Bolivian Boliviano long-term exchange rate of 6.85 and discount rates ranging from 8.25% - 12.25% (to reflect project and country-specific risks). During 2013, 2012 and 2011, we recorded impairments of $773.0 million ($642.1 million impairment of the Palmarejo mine and a $130.7 million impairment of the Kensington mine), $5.8 million (Martha mine), and nil, respectively, to reduce the carrying value of mining properties and property, plant and equipment as part of Write-downs.
Existing proven and probable reserves and value beyond proven and probable reserves, including mineralization other than proven and probable reserves are included when determining the fair value of mine site asset groups at acquisition and, subsequently, in determining whether the assets are impaired. The term “recoverable minerals” refers to the estimated amount of silver and gold that will be obtained after taking into account losses during ore processing and treatment. Estimates of recoverable minerals from exploration stage mineral interests are risk adjusted based on management’s relative confidence in such materials. The ability to achieve the estimated quantities of recoverable minerals from exploration stage mineral interests involves further risks in addition to those risk factors applicable to mineral interests where proven and probable
Coeur Mining, Inc. | 104 S. Michigan Ave., Suite 900 | Chicago, Illinois 60603 | t: 312-489-5843 | f: 312-489-5897 | www.coeur.com
reserves have been identified, due to the lower level of confidence that the identified mineralized material could ultimately be mined economically. Assets classified as exploration potential have the highest level of risk that the carrying value of the asset can be ultimately realized, due to the still lower level of geological confidence and economic modeling.
Silver and gold prices are volatile and affected by many factors beyond the Company’s control, including prevailing interest rates and returns on other asset classes, expectations regarding inflation, speculation, currency values, governmental decisions regarding precious metals stockpiles, global and regional demand and production, political and economic conditions and other factors may affect the key assumptions used in the Company’s impairment testing. Various factors could impact our ability to achieve forecasted production levels from proven and probable reserves. Additionally, production, capital and reclamation costs could differ from the assumptions used in the cash flow models used to assess impairment. Actual results may vary from the Company’s estimates and result in additional Write-downs.
Liquidity and Capital Resources, page 40
Cash provided by operating activities, page 40
2.
We note significant changes in your cash flows from operating activities during the periods presented, for example, cash provided by operating activities decreased by $145 million and $158 million during 2012 and 2013, respectively. We note that you have provided a general discussion for the reasons for the change. However, your discussions did not clearly identify the specific quantitative effect of the underlying causal factors responsible for the change. To enhance an investor’s understanding, please confirm that in future filings you will include robust discussions describing and quantifying the specific effect of the significant drivers that contributed to the material changes in your operating cash flows. Please provide us with a draft of proposed disclosures to be included in future filings. Refer to Item 303 of Regulations S-K and SEC Release No. 33-8350 as it relates to liquidity and capital resources for further guidance.
The Company confirms it will provide a more robust discussion in future filings to quantify the specific effects of significant drivers to material changes in operating cash flows. An example of the disclosure that would have been included in the Annual Report is as follows:
Cash Provided by Operating Activities
Net cash provided by operating activities was $113.5 million, $271.6 million and $416.2 million for the years ended December 31, 2013, 2012 and 2011, respectively and were impacted by the following key factors:
Year Ended December 31,
Silver equivalent ounces sold (excluding Kensington)
26,008,123
26,453,889
26,975,524
Average realized price per silver equivalent ounce
$
22.96
$
29.66
$
32.25
Costs applicable to sales per silver equivalent ounce (1)
(13.81
)
(13.89
)
(11.78
)
Operating margin per silver equivalent ounce
$
9.15
$
15.77
$
20.47
Gold ounces sold (Kensington)
117,500
71,709
106,583
Average realized price per gold ounce
$
1,266
$
1,548
$
1,418
Costs applicable to sales per gold ounce (1)
(890
)
(1,214
)
(950
)
Operating margin per gold ounce
$
$
$
(1) See Non-GAAP Performance Measures
Coeur Mining, Inc. | 104 S. Michigan Ave., Suite 900 | Chicago, Illinois 60603 | t: 312-489-5843 | f: 312-489-5897 | www.coeur.com
Year Ended December 31,
(in thousands)
Cash flow before changes in operating assets and liabilities
$
149,848
$
338,713
$
454,380
Changes in operating assets and liabilities:
Receivables and other current assets
9,756
(21,950
)
Prepaid expenses and other
(15,165
)
2,489
(8,839
)
Inventories
4,031
(48,305
)
(30,408
)
Accounts payable and accrued liabilities
(25,910
)
(31,019
)
22,990
CASH PROVIDED BY OPERATING ACTIVITIES
$
113,467
$
271,634
$
416,173
Cash provided by operating activities decreased $158.2 million in 2013 compared to 2012 primarily due to lower average realized silver and gold prices and lower silver ounces sold, partially offset by higher gold ounces sold, lower costs applicable to sales per gold ounce and a smaller increase to working capital. 2013 metal sales were $207.3 million lower due to lower average realized prices, partially offset by $57.8 million due to higher sales volumes. Cash provided by operating activities decreased $144.6 million in 2012 compared to 2011 primarily due to a lower average realized silver price, lower silver and gold ounces sold, higher costs applicable to sales and a larger increase in working capital, partially offset by a higher average realized gold price. 2012 metal sales were $59.4 million lower due to lower average realized prices and $66.3 million lower due to lower sales volumes.
The Company’s financial position at December 31, 2013, and the expected operating cash flows over the next twelve months, lead management to believe that the Company’s liquid assets are sufficient to fund currently planned capital expenditures for existing operations and to discharge liabilities as they come due. Please refer to the “Looking Forward” section of this MD&A for a more detailed description of capital expenditures planned for 2014. The Company remains well-positioned to take advantage of strategic opportunities as they become available.
Overview of Mining Properties and Interests, page 3
Business Strategy and Competitive Strengths, page 8
Risk Factors, page 13 and 14
Argentina - Joaquin Mine, page 23 and 24
Looking Forward, page 32
Foreign Currency Contracts and Hedges, page 48
Note 10 - Acquisitions, page F-23
3. We note you refer to the Joaquin and the La Preciosa properties as development stage properties at the above locations and elsewhere in your filing. The terms development and production have very specific meanings within Industry Guide 7 (see www.sec.gov/about/forms/industryguides.pdf). These words/terms reference the development stage when preparing reserves for production, and the production stage when companies are engaged in commercial-scale, profit-oriented extraction of minerals. Since you do not disclose any reserves for these properties, as defined by Guide 7, please remove the terms develop, development or production throughout your document, and replace this terminology, as needed, with the terms such as explore or exploration.
The Company will remove in future filings the terms develop, development and production when referring to our Joaquin and La Preciosa projects and ensure all descriptive terms are in compliance with Industry Guide 7. The Company does not believe the use of these terms in prior filings would be material to readers of the Company’s financial statements.
Coeur Mining, Inc. | 104 S. Michigan Ave., Suite 900 | Chicago, Illinois 60603 | t: 312-489-5843 | f: 312-489-5897 | www.coeur.com
4. We note your royalty properties, Cerro Bayo, El Gallo/Magistral, and Zaruma are properties with reserves or mineralized materials that are not disclosed or updated in your filing. Please modify your filing and provide updated reserve/mineralized material estimates for all your royalty properties, ideally to coincide with your fiscal year end.
The Company is pursuing a larger footprint in the royalty business, as demonstrated by the December 2013 acquisition of Global Royalty Corporation and reporting Coeur Capital as a new reportable segment at December 31, 2013. The Coeur Capital segment includes the Company’s Endeavor silver stream and royalty properties. Coeur Capital’s revenues and expenses are predominantly from the Endeavor silver stream for which all relevant reserve and production data is disclosed in the Company’s filings. At December 31, 2013, royalty properties represented 1.9% of consolidated mining properties and 1.2% of consolidated assets. At June 30, 2014, royalty revenue represented 0.6% of the Company’s consolidated revenue. Given the limited nature of the Company’s royalty properties, management believes the general property description and disclosure of consolidated royalty revenue included in the Company’s filings to be appropriate from a quantitative and qualitative perspective. The Company will continue to review and enhance its disclosures when appropriate as Coeur Capital’s portfolio grows.
5. A portion of your revenues is dependent on the mine production that occurs at your royalty properties, but we note you do not report the silver or the funds received, nor do you report the tonnage and grade mined and/or processed at these respective properties, nor do you report the saleable metals on which your royalty revenues are based. Please revise your filing to include detailed production information, saleable metals, and revenues received for each of your royalty properties.
We respectfully refer the Staff to the Company’s response to Comment No. 4. Given the limited nature of the Company’s interest in royalty properties, management believes the revenue disclosures with respect to such properties to be appropriate from a quantitative
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CORRESP 1 filename1.htm 4Q14 CDE SEC Comment Letter November 19, 2014 VIA EDGAR AND HAND DELIVERY Ms. Tia L. Jenkins Senior Assistant Chief Accountant Office of Beverages, Apparel, and Mining Division of Corporation Finance U.S. Securities and Exchange Commission 100 F Street, N.E. Washington, D.C. 20549 Re: Coeur Mining, Inc. Form 10-K for the Year Ended December 31, 2013 Filed February 26, 2014 File No. 001-08641 Dear Ms. Jenkins: On behalf of Coeur Mining, Inc. (the “Company”), this letter responds to your letter, dated November 6, 2014 (the “Comment Letter”), regarding the above-referenced Annual Report on Form 10‑K for the year ended December 31, 2013 (the “Annual Report”), filed with the Securities and Exchange Commission (the “Commission”) on February 26, 2014. Each comment of the Staff of the Division of Corporation Finance of the Commission (the “Staff”) is set forth below, followed by the corresponding response. For ease of reference, the headings and numbered paragraphs below correspond to the headings and numbered comments in the Comment Letter. Each response of the Company is set forth in ordinary type beneath the corresponding comment of the Staff appearing in bold type. Form 10-K for the Year Ended December 31, 2013 Management’s Discussion and Analysis of Financial Condition and Results of Operations, page 31 Critical Accounting Policies and Developments - Impairments, page 33 1. We note your disclosure under Note 4 that you recorded an impairment charge of $773 million to mining properties in 2013. Considering your impairment charges and significant decline in your realized silver and gold prices during the periods reported, to enhance investor’s understanding regarding your recent impairment testing of long lived assets, please confirm that you will disclose the following in future filings: Coeur Mining, Inc. | 104 S. Michigan Ave., Suite 900 | Chicago, Illinois 60603 | t: 312-489-5843 | f: 312-489-5897 | www.coeur.com • the amount of long-lived assets (mineral interests and property, plant and equipment) allocated to each of the asset groups that are at risk of impairment and the percentage by which fair value exceeded carrying value as of the date of the most recent test; • a description of the methods and key assumptions used and how the key assumptions were determined; • a discussion of the degree of uncertainty associated with the key assumptions in as specific a manner as practicable; • the factors that affect variability in the pricing assumptions; and, • a description of potential events and/or changes in circumstances that could reasonably be expected to negatively affect the key assumptions. Please provide us with a draft of your proposed disclosures. Refer to FR-72, which can be found on our website at: http://www.sec.gov/rules/interp/33-8350.htm. At December 31, 2013, the Company identified impairment triggering events at its Palmarejo and Kensington mines. The triggering events identified were sustained and continued operating losses combined with results of the revised life-of-mine plans for those two mines. The Company did not identify any additional triggering events nor has the Company recorded any goodwill associated with its mining properties or other assets, and therefore, in accordance with FASB ASC 360, the Company did not conduct further impairment testing. The Company confirms it will enhance its Critical Accounting Policies and Developments - Impairments discussion in future filings to include more specific detail related to key assumptions used in impairment testing and related risk and uncertainties associated with those key assumptions. An example of the disclosure that would have been included in the Annual Report is as follows: Impairments We review and evaluate our long-lived assets for impairment when events or changes in circumstances indicate that the related carrying amounts may not be recoverable. Asset impairment is considered to exist if the total estimated undiscounted pre-tax future cash flows are less than the carrying amount of the asset. In estimating future cash flows, assets are grouped at the lowest level for which there is identifiable cash flows that are largely independent of future cash flows from other asset groups. An impairment loss is measured and recorded based on discounted estimated future cash flows. Future cash flows are estimated based on estimated quantities of recoverable minerals, expected silver and gold prices (considering current and historical prices, trends and related factors), production levels, operating costs, capital requirements and reclamation costs, all based on life-of-mine plans. The significant assumptions used in determining future cash flows for each mine site asset group at December 31, 2013, apart from production cost and capitalized expenditure assumptions unique to each operation, included long-term silver and gold prices of $25 and $1,450 per ounce (consistent with the Company’s long-term reserve prices), respectively, a U.S. to Mexican Peso long-term exchange rate of 12.5, a U.S. to Bolivian Boliviano long-term exchange rate of 6.85 and discount rates ranging from 8.25% - 12.25% (to reflect project and country-specific risks). During 2013, 2012 and 2011, we recorded impairments of $773.0 million ($642.1 million impairment of the Palmarejo mine and a $130.7 million impairment of the Kensington mine), $5.8 million (Martha mine), and nil, respectively, to reduce the carrying value of mining properties and property, plant and equipment as part of Write-downs. Existing proven and probable reserves and value beyond proven and probable reserves, including mineralization other than proven and probable reserves are included when determining the fair value of mine site asset groups at acquisition and, subsequently, in determining whether the assets are impaired. The term “recoverable minerals” refers to the estimated amount of silver and gold that will be obtained after taking into account losses during ore processing and treatment. Estimates of recoverable minerals from exploration stage mineral interests are risk adjusted based on management’s relative confidence in such materials. The ability to achieve the estimated quantities of recoverable minerals from exploration stage mineral interests involves further risks in addition to those risk factors applicable to mineral interests where proven and probable Coeur Mining, Inc. | 104 S. Michigan Ave., Suite 900 | Chicago, Illinois 60603 | t: 312-489-5843 | f: 312-489-5897 | www.coeur.com reserves have been identified, due to the lower level of confidence that the identified mineralized material could ultimately be mined economically. Assets classified as exploration potential have the highest level of risk that the carrying value of the asset can be ultimately realized, due to the still lower level of geological confidence and economic modeling. Silver and gold prices are volatile and affected by many factors beyond the Company’s control, including prevailing interest rates and returns on other asset classes, expectations regarding inflation, speculation, currency values, governmental decisions regarding precious metals stockpiles, global and regional demand and production, political and economic conditions and other factors may affect the key assumptions used in the Company’s impairment testing. Various factors could impact our ability to achieve forecasted production levels from proven and probable reserves. Additionally, production, capital and reclamation costs could differ from the assumptions used in the cash flow models used to assess impairment. Actual results may vary from the Company’s estimates and result in additional Write-downs. Liquidity and Capital Resources, page 40 Cash provided by operating activities, page 40 2. We note significant changes in your cash flows from operating activities during the periods presented, for example, cash provided by operating activities decreased by $145 million and $158 million during 2012 and 2013, respectively. We note that you have provided a general discussion for the reasons for the change. However, your discussions did not clearly identify the specific quantitative effect of the underlying causal factors responsible for the change. To enhance an investor’s understanding, please confirm that in future filings you will include robust discussions describing and quantifying the specific effect of the significant drivers that contributed to the material changes in your operating cash flows. Please provide us with a draft of proposed disclosures to be included in future filings. Refer to Item 303 of Regulations S-K and SEC Release No. 33-8350 as it relates to liquidity and capital resources for further guidance. The Company confirms it will provide a more robust discussion in future filings to quantify the specific effects of significant drivers to material changes in operating cash flows. An example of the disclosure that would have been included in the Annual Report is as follows: Cash Provided by Operating Activities Net cash provided by operating activities was $113.5 million, $271.6 million and $416.2 million for the years ended December 31, 2013, 2012 and 2011, respectively and were impacted by the following key factors: Year Ended December 31, 2013 2012 2011 Silver equivalent ounces sold (excluding Kensington) 26,008,123 26,453,889 26,975,524 Average realized price per silver equivalent ounce $ 22.96 $ 29.66 $ 32.25 Costs applicable to sales per silver equivalent ounce (1) (13.81 ) (13.89 ) (11.78 ) Operating margin per silver equivalent ounce $ 9.15 $ 15.77 $ 20.47 Gold ounces sold (Kensington) 117,500 71,709 106,583 Average realized price per gold ounce $ 1,266 $ 1,548 $ 1,418 Costs applicable to sales per gold ounce (1) (890 ) (1,214 ) (950 ) Operating margin per gold ounce $ 376 $ 334 $ 468 (1) See Non-GAAP Performance Measures Coeur Mining, Inc. | 104 S. Michigan Ave., Suite 900 | Chicago, Illinois 60603 | t: 312-489-5843 | f: 312-489-5897 | www.coeur.com Year Ended December 31, (in thousands) 2013 2012 2011 Cash flow before changes in operating assets and liabilities $ 149,848 $ 338,713 $ 454,380 Changes in operating assets and liabilities: Receivables and other current assets 663 9,756 (21,950 ) Prepaid expenses and other (15,165 ) 2,489 (8,839 ) Inventories 4,031 (48,305 ) (30,408 ) Accounts payable and accrued liabilities (25,910 ) (31,019 ) 22,990 CASH PROVIDED BY OPERATING ACTIVITIES $ 113,467 $ 271,634 $ 416,173 Cash provided by operating activities decreased $158.2 million in 2013 compared to 2012 primarily due to lower average realized silver and gold prices and lower silver ounces sold, partially offset by higher gold ounces sold, lower costs applicable to sales per gold ounce and a smaller increase to working capital. 2013 metal sales were $207.3 million lower due to lower average realized prices, partially offset by $57.8 million due to higher sales volumes. Cash provided by operating activities decreased $144.6 million in 2012 compared to 2011 primarily due to a lower average realized silver price, lower silver and gold ounces sold, higher costs applicable to sales and a larger increase in working capital, partially offset by a higher average realized gold price. 2012 metal sales were $59.4 million lower due to lower average realized prices and $66.3 million lower due to lower sales volumes. The Company’s financial position at December 31, 2013, and the expected operating cash flows over the next twelve months, lead management to believe that the Company’s liquid assets are sufficient to fund currently planned capital expenditures for existing operations and to discharge liabilities as they come due. Please refer to the “Looking Forward” section of this MD&A for a more detailed description of capital expenditures planned for 2014. The Company remains well-positioned to take advantage of strategic opportunities as they become available. Overview of Mining Properties and Interests, page 3 Business Strategy and Competitive Strengths, page 8 Risk Factors, page 13 and 14 Argentina - Joaquin Mine, page 23 and 24 Looking Forward, page 32 Foreign Currency Contracts and Hedges, page 48 Note 10 - Acquisitions, page F-23 3. We note you refer to the Joaquin and the La Preciosa properties as development stage properties at the above locations and elsewhere in your filing. The terms development and production have very specific meanings within Industry Guide 7 (see www.sec.gov/about/forms/industryguides.pdf). These words/terms reference the development stage when preparing reserves for production, and the production stage when companies are engaged in commercial-scale, profit-oriented extraction of minerals. Since you do not disclose any reserves for these properties, as defined by Guide 7, please remove the terms develop, development or production throughout your document, and replace this terminology, as needed, with the terms such as explore or exploration. The Company will remove in future filings the terms develop, development and production when referring to our Joaquin and La Preciosa projects and ensure all descriptive terms are in compliance with Industry Guide 7. The Company does not believe the use of these terms in prior filings would be material to readers of the Company’s financial statements. Coeur Mining, Inc. | 104 S. Michigan Ave., Suite 900 | Chicago, Illinois 60603 | t: 312-489-5843 | f: 312-489-5897 | www.coeur.com 4. We note your royalty properties, Cerro Bayo, El Gallo/Magistral, and Zaruma are properties with reserves or mineralized materials that are not disclosed or updated in your filing. Please modify your filing and provide updated reserve/mineralized material estimates for all your royalty properties, ideally to coincide with your fiscal year end. The Company is pursuing a larger footprint in the royalty business, as demonstrated by the December 2013 acquisition of Global Royalty Corporation and reporting Coeur Capital as a new reportable segment at December 31, 2013. The Coeur Capital segment includes the Company’s Endeavor silver stream and royalty properties. Coeur Capital’s revenues and expenses are predominantly from the Endeavor silver stream for which all relevant reserve and production data is disclosed in the Company’s filings. At December 31, 2013, royalty properties represented 1.9% of consolidated mining properties and 1.2% of consolidated assets. At June 30, 2014, royalty revenue represented 0.6% of the Company’s consolidated revenue. Given the limited nature of the Company’s royalty properties, management believes the general property description and disclosure of consolidated royalty revenue included in the Company’s filings to be appropriate from a quantitative and qualitative perspective. The Company will continue to review and enhance its disclosures when appropriate as Coeur Capital’s portfolio grows. 5. A portion of your revenues is dependent on the mine production that occurs at your royalty properties, but we note you do not report the silver or the funds received, nor do you report the tonnage and grade mined and/or processed at these respective properties, nor do you report the saleable metals on which your royalty revenues are based. Please revise your filing to include detailed production information, saleable metals, and revenues received for each of your royalty properties. We respectfully refer the Staff to the Company’s response to Comment No. 4. Given the limited nature of the Company’s interest in royalty properties, management believes the revenue disclosures with respect to such properties to be appropriate from a quantitative