SEC Comment Letter for CHINA NATURAL RESOURCES INC (CHNR) (CIK 0000793628) (CHNR) — Feb 13, 2013
CHINA NATURAL RESOURCES INC (CHNR) (CIK 0000793628)
Date: Feb. 13, 2013 · CIK: 0000793628 · Accession: 0000000000-13-008408
AI Filing Summary & Sentiment
Reasoning
Referenced dates: December 21, 2012
Letter
February 13, 201 3 Via E-mail Mr. Feilie Li Chief Executive Officer China Natural Resources, Inc. Shun Tak Centre, West Tower, Room 2205 168-200 Connaught Road Central Sheung Wan, Hong Kong
Re: China Natural Resources, Inc. Form 20 -F for Fiscal Year Ended December 31, 2011 Filed April 27, 2012 Response dated January 25, 2013 File No. 000 -26046
Dear Mr. Li:
We have reviewed your response 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 this letter within ten business days by amending your filing, by providing the requested information , or by advising us when you will provide the requested response. If you do not believe our comments apply to your facts and circumstances, or do not believe an amendment is appropriate, please tell us why in your response.
After reviewing any amendment t o your filing and the information you provide in response to these comments, we may have additional comments.
Form 20 -F for Fiscal Year Ended December 31, 2011
Coal Mining Operations page 31
1. We note your response to comment 3 from our letter dated December 21, 2012. Additionally we note from you r disclosure that your coal reserves are JORC compliant and that they may differ substantially from the protocols recognized in the United States. Only mineral reserve s meeting the standards and terminology defined within Industry Guide 7 may be disclosed in filings with the United States Securities and Exchange Commission . In future filings please provide additional disclosure to clarify.
2. We note that your materials designated as non -reserve coal are a lso defined as inferred resources. A non -reserve coal deposit is a coal bearing body that has been sufficiently
Mr. Feilie Li China Natural Resources, Inc. February 13, 201 3 Page 2
sampled and analyzed in trenches, outcrops, drilling and underground workings to assume continuity between sample points, and therefore warrant s further exploration stage work. This coal does not qualify as a commercially viable coal reserve until a final comprehensive evaluation based upon unit cost per ton, recoverability, and other material factors concludes legal and economic feasibility. No n-reserve coal deposits should not be based on geologic inference. In future filings please remove any non -reserve materials that are based on geologic inference.
3. In future filings please ensure your mineral reserves correspond to your fiscal year end .
You may contact John Coleman, Mining Engineer, at (202) 551 -3610 with questions about engineering comments. Please contact me at (202) 551 -3871 with any other questions.
Sincerely,
/s/Tia L. Jenkins
Show Raw Text
February 13, 201 3
Via E-mail
Mr. Feilie Li
Chief Executive Officer
China Natural Resources, Inc.
Shun Tak Centre, West Tower, Room 2205
168-200 Connaught Road Central
Sheung Wan, Hong Kong
Re: China Natural Resources, Inc.
Form 20 -F for Fiscal Year Ended December 31, 2011
Filed April 27, 2012
Response dated January 25, 2013
File No. 000 -26046
Dear Mr. Li:
We have reviewed your response 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 this letter within ten business days by amending your filing, by
providing the requested information , or by advising us when you will provide the requested
response. If you do not believe our comments apply to your facts and circumstances, or do not
believe an amendment is appropriate, please tell us why in your response.
After reviewing any amendment t o your filing and the information you provide in
response to these comments, we may have additional comments.
Form 20 -F for Fiscal Year Ended December 31, 2011
Coal Mining Operations page 31
1. We note your response to comment 3 from our letter dated December 21, 2012.
Additionally we note from you r disclosure that your coal reserves are JORC compliant
and that they may differ substantially from the protocols recognized in the United States.
Only mineral reserve s meeting the standards and terminology defined within Industry
Guide 7 may be disclosed in filings with the United States Securities and Exchange
Commission . In future filings please provide additional disclosure to clarify.
2. We note that your materials designated as non -reserve coal are a lso defined as inferred
resources. A non -reserve coal deposit is a coal bearing body that has been sufficiently
Mr. Feilie Li
China Natural Resources, Inc.
February 13, 201 3
Page 2
sampled and analyzed in trenches, outcrops, drilling and underground workings to
assume continuity between sample points, and therefore warrant s further exploration
stage work. This coal does not qualify as a commercially viable coal reserve until a final
comprehensive evaluation based upon unit cost per ton, recoverability, and other material
factors concludes legal and economic feasibility. No n-reserve coal deposits should not be
based on geologic inference. In future filings please remove any non -reserve materials
that are based on geologic inference.
3. In future filings please ensure your mineral reserves correspond to your fiscal year end .
You may contact John Coleman, Mining Engineer, at (202) 551 -3610 with questions
about engineering comments. Please contact me at (202) 551 -3871 with any other questions.
Sincerely,
/s/Tia L. Jenkins
Tia L. Jenkins
Senior Assistant Chief Accountan t
Office of Beverages, Apparel, and
Mining