SEC Comment Letter for PAN AMERICAN SILVER CORP (PAAS, PAASF) (CIK 0000771992) (PAAS) — May 28, 2020
PAN AMERICAN SILVER CORP (PAAS, PAASF) (CIK 0000771992)
Date: May 28, 2020 · CIK: 0000771992 · Accession: 0000000000-20-004761
AI Filing Summary & Sentiment
File numbers found in text: 000-13727
Letter
United States securities and exchange commission logo May 28, 2020 A. Robert Doyle Chief Financial Officer Pan American Silver Corporation 1500-625 Howe Street Vancouver, British Columbia V6C 2T6 Re:Pan American Silver Corp. Form 40-F for the Year Ended December 31, 2019 Filed March 12, 2020 File No. 000-13727 Dear Mr. Doyle: We have reviewed your filing and have the following comment. Please respond to this comment 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 our comment applies to your facts and circumstances, please tell us why in your response. After reviewing your response to this comment, we may have additional comments. Form 40-F for the Year Ended December 31, 2019 Exhibit 1.3 Audited Consolidated Financial Statements Note 8 - Tahoe Acquisition, page 32 1.You disclose that you determined the fair value of the contingent value rights issued to the Tahoe shareholders based on a residual amount of the Tahoe shares acquired less the cash consideration and fair value of the Pan American shares you issued. Please tell us how your determination of the acquisition-date fair value of the contingent value rights is consistent with paragraph 39 of IFRS3 and the fair value measurement principles and valuation techniques of IFRS13. 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.
FirstName LastNameA. Robert Doyle Comapany NamePan American Silver Corporation May 28, 2020 Page 2 FirstName LastName A. Robert Doyle Pan American Silver Corporation May 28, 2020 Page 2 You may contact Brian McAllister, Staff Accountant, at (202) 551-3341 or Craig Arakawa, Accounting Branch Chief, at (202) 551-3650 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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United States securities and exchange commission logo
May 28, 2020
A. Robert Doyle
Chief Financial Officer
Pan American Silver Corporation
1500-625 Howe Street
Vancouver, British Columbia
V6C 2T6
Re:Pan American Silver Corp.
Form 40-F for the Year Ended December 31, 2019
Filed March 12, 2020
File No. 000-13727
Dear Mr. Doyle:
We have reviewed your filing and have the following comment.
Please respond to this comment 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 our
comment applies to your facts and circumstances, please tell us why in your response.
After reviewing your response to this comment, we may have additional comments.
Form 40-F for the Year Ended December 31, 2019
Exhibit 1.3 Audited Consolidated Financial Statements
Note 8 - Tahoe Acquisition, page 32
1.You disclose that you determined the fair value of the contingent value rights issued to the
Tahoe shareholders based on a residual amount of the Tahoe shares acquired less the cash
consideration and fair value of the Pan American shares you issued. Please tell us how
your determination of the acquisition-date fair value of the contingent value rights is
consistent with paragraph 39 of IFRS3 and the fair value measurement principles and
valuation techniques of IFRS13.
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.
FirstName LastNameA. Robert Doyle
Comapany NamePan American Silver Corporation
May 28, 2020 Page 2
FirstName LastName
A. Robert Doyle
Pan American Silver Corporation
May 28, 2020
Page 2
You may contact Brian McAllister, Staff Accountant, at (202) 551-3341 or Craig
Arakawa, Accounting Branch Chief, at (202) 551-3650 if you have questions regarding
comments on the financial statements and related matters.
Sincerely,
Division of Corporation Finance
Office of Energy & Transportation