SEC Comment Letter 0000000000-22-013450 to VISTA GOLD CORP (VGZ) (CIK 0000783324) (VGZ)
VISTA GOLD CORP (VGZ) (CIK 0000783324)
Date: Dec. 14, 2022 · CIK: 0000783324 · Accession: 0000000000-22-013450
AI Filing Summary & Sentiment
File numbers found in text: 001-09025
Letter
United States securities and exchange commission logo December 14, 2022 Douglas Tobler Chief Financial Officer Vista Gold Corp. 7961 Shaffer Parkway, Suite 5 Littleton, Colorado 80127 Re:Vista Gold Corp Form 10-K for the Fiscal Year Ended December 31, 2021 Filed February 24, 2022 File No. 001-09025 Dear Douglas Tobler: We have reviewed your filing 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 business days by providing the requested information or advise 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. Form 10-K for the Fiscal Year Ended December 31, 2021 Filed February 24, 2022 Item 2. Properties, page 28 1.Please disclose mineral resources exclusive of mineral reserves as required by Item 1304(d)(2) of Regulation S-K, and state the point of reference used when estimating mineral resources. Exhibits 96.1, page 82 2.Please revise your technical report to disclose mineral resources exclusive of mineral reserves as required by Item 601(b)(96)(iii)(11)(ii) of Regulation S-K, and state the point of reference used when estimating mineral resources.
FirstName LastNameDouglas Tobler Comapany NameVista Gold Corp. December 14, 2022 Page 2 FirstName LastName Douglas Tobler Vista Gold Corp. December 14, 2022 Page 2 3.Please revise your technical report to include the qualified person opinions as required under Items 601(b)(96)(iii)(10)(v) and 17(vi) of Regulation S-K. 4.We note the disclosure on page 298 of your technical report stating that the level of accuracy of the project cost estimate is considered +- 25%. Items 1302(e)(9) and (e)(12) of Regulation S-K specify minimum accuracy levels with respect to the type of feasibility study performed. Please tell us the level of study contemplated by your technical report and, if necessary, revise your disclosures to clarify. 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 John Coleman at 202-551-3610 or Craig Arakawa at 202-551-3650 if you have questions regarding comments.s. Sincerely, Division of Corporation Finance Office of Energy & Transportation cc: Doug Tobler
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United States securities and exchange commission logo
December 14, 2022
Douglas Tobler
Chief Financial Officer
Vista Gold Corp.
7961 Shaffer Parkway, Suite 5
Littleton, Colorado 80127
Re:Vista Gold Corp
Form 10-K for the Fiscal Year Ended December 31, 2021
Filed February 24, 2022
File No. 001-09025
Dear Douglas Tobler:
We have reviewed your filing 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 business days by providing the requested
information or advise 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.
Form 10-K for the Fiscal Year Ended December 31, 2021 Filed February 24, 2022
Item 2. Properties, page 28
1.Please disclose mineral resources exclusive of mineral reserves as required by Item
1304(d)(2) of Regulation S-K, and state the point of reference used when estimating
mineral resources.
Exhibits
96.1, page 82
2.Please revise your technical report to disclose mineral resources exclusive of mineral
reserves as required by Item 601(b)(96)(iii)(11)(ii) of Regulation S-K, and state the point
of reference used when estimating mineral resources.
FirstName LastNameDouglas Tobler
Comapany NameVista Gold Corp.
December 14, 2022 Page 2
FirstName LastName
Douglas Tobler
Vista Gold Corp.
December 14, 2022
Page 2
3.Please revise your technical report to include the qualified person opinions as required
under Items 601(b)(96)(iii)(10)(v) and 17(vi) of Regulation S-K.
4.We note the disclosure on page 298 of your technical report stating that the level of
accuracy of the project cost estimate is considered +- 25%. Items 1302(e)(9) and (e)(12)
of Regulation S-K specify minimum accuracy levels with respect to the type of feasibility
study performed. Please tell us the level of study contemplated by your technical report
and, if necessary, revise your disclosures to clarify.
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 John Coleman at 202-551-3610 or Craig Arakawa at 202-551-3650 if
you have questions regarding comments.s.
Sincerely,
Division of Corporation Finance
Office of Energy & Transportation
cc: Doug Tobler