Correspondence 0001477932-24-003933 from AVINO SILVER & GOLD MINES LTD (ASM) (CIK 0000316888) (ASM)
AVINO SILVER & GOLD MINES LTD (ASM) (CIK 0000316888)
Date: June 28, 2024 · CIK: 0000316888 · Accession: 0001477932-24-003933
AI Filing Summary & Sentiment
File numbers found in text: 001-35254
Referenced dates: June 13, 2024
Letter
VIA EDGAR Division of Corporation Finance Office of Energy & Transportation Avino Silver & Gold Mines Ltd Form 40-F for the Fiscal Year Ended December 31, 2023 Filed March 29, 2024 File No. 001-35254
Dear Mr. Pawar:
Avino Silver & Gold Mines Ltd. (the “Company,” “we,” “our” or “us”) hereby transmits our response to the comment letter received from the staff (the “Staff,” “you” or “your”) of the U.S. Securities and Exchange Commission (the “Commission”), dated June 13, 2024, regarding the Company’s Form 40-F for the fiscal year ended December 31, 2023, filed with the Commission on March 29, 2024. In response to the Staff’s comments, the Company is submitting this response letter. For your convenience, we have repeated below your comment in bold, and have followed the comment with our response.
Exhibit 99.2
Note 3. Material Accounting Policies
(i) Exploration and evaluation expenditures, page 15
1.
Your accounting policy states that proceeds from the sale of mineral products or farm outs during the exploration and evaluation stage are deducted from the related capitalized costs. Please explain how this policy complies with the guidance in Property, Plant and Equipment - Proceeds before Intended Use, Amendments to IAS 16, which became effective for annual reporting periods beginning on or after January 1, 2022. Please also tell us the amount of revenues that were deducted from capitalized costs for both fiscal years ended December 31, 2023 and 2022.
In response to the Staff’s comment, the Company notes that this paragraph in our “Exploration and evaluation assets and development costs” section within our Material Accounting Policies should have been updated to remove the reference to “proceeds from the sale of mineral products or farm outs during the exploration and evaluation stage are deducted from the related capitalized costs” as the amendments under IAS 16 were adopted by the Company effective January 1, 2022, and the policy as presented includes a typographical error.
The amount of revenues that were deducted from capitalized costs for both fiscal years ended December 31, 2023 and 2022, were Nil and Nil, as this is not permitted under the Amendments to IAS 16. There were no sales of mineral products or farms outs in the exploration and evaluation stage during the fiscal years ended December 31, 2023 and 2022. The Company will update its accounting policy in its financial statements for the year ending December 31, 2024, to be included in the Form 40-F.
If you have further comments, please feel free to contact to the undersigned at nharte@avino.com or by telephone at (604) 682-3701.
Sincerely,
/s/ Nathan Harte
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ASM: TSX/NYSE American
Avino Silver & Gold Mines Ltd.
Suite 900-570 Granville Street
Vancouver, BC V6C 3P1
T (604) 682 3701
F (604) 682 3600
www.avino.com
VIA EDGAR
June 27, 2024
U.S. Securities & Exchange Commission
Division of Corporation Finance
Office of Energy & Transportation
100 F Street, NE
Washington, D.C. 20549
Attn: Ranjit Singh Pawar
Re:
Avino Silver & Gold Mines Ltd
Form 40-F for the Fiscal Year Ended December 31, 2023
Filed March 29, 2024
File No. 001-35254
Dear Mr. Pawar:
Avino Silver & Gold Mines Ltd. (the “Company,” “we,” “our” or “us”) hereby transmits our response to the comment letter received from the staff (the “Staff,” “you” or “your”) of the U.S. Securities and Exchange Commission (the “Commission”), dated June 13, 2024, regarding the Company’s Form 40-F for the fiscal year ended December 31, 2023, filed with the Commission on March 29, 2024. In response to the Staff’s comments, the Company is submitting this response letter. For your convenience, we have repeated below your comment in bold, and have followed the comment with our response.
Exhibit 99.2
Note 3. Material Accounting Policies
(i) Exploration and evaluation expenditures, page 15
1.
Your accounting policy states that proceeds from the sale of mineral products or farm outs during the exploration and evaluation stage are deducted from the related capitalized costs. Please explain how this policy complies with the guidance in Property, Plant and Equipment - Proceeds before Intended Use, Amendments to IAS 16, which became effective for annual reporting periods beginning on or after January 1, 2022. Please also tell us the amount of revenues that were deducted from capitalized costs for both fiscal years ended December 31, 2023 and 2022.
In response to the Staff’s comment, the Company notes that this paragraph in our “Exploration and evaluation assets and development costs” section within our Material Accounting Policies should have been updated to remove the reference to “proceeds from the sale of mineral products or farm outs during the exploration and evaluation stage are deducted from the related capitalized costs” as the amendments under IAS 16 were adopted by the Company effective January 1, 2022, and the policy as presented includes a typographical error.
The amount of revenues that were deducted from capitalized costs for both fiscal years ended December 31, 2023 and 2022, were Nil and Nil, as this is not permitted under the Amendments to IAS 16. There were no sales of mineral products or farms outs in the exploration and evaluation stage during the fiscal years ended December 31, 2023 and 2022. The Company will update its accounting policy in its financial statements for the year ending December 31, 2024, to be included in the Form 40-F.
If you have further comments, please feel free to contact to the undersigned at nharte@avino.com or by telephone at (604) 682-3701.
Sincerely,
/s/ Nathan Harte
Nathan Harte
Chief Financial Officer
cc:
Daniel Eng
Lewis Brisbois
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