SEC Comment Letter for Premium Resources Ltd. (PRMLF) (CIK 0000795800) (NEXM) — Sep 14, 2017
Premium Resources Ltd. (PRMLF) (CIK 0000795800)
Date: Sept. 14, 2017 · CIK: 0000795800 · Accession: 0000000000-17-032706
AI Filing Summary & Sentiment
Letter
Mail Stop 3561 September 14, 2017 Via E -mail Mr. Keith Morrison Chief Executive Officer North American Nickel Inc. 1055 West Hastings Street Suite 2200 Vancouver, British Columbia V6E 2E9 Canada
Re: North American Nickel Inc. Form 20 -F for Fiscal Year Ended December 31, 2016 Filed April 24, 2017 File No. 000 -14740
Dear Mr. Morrison :
We have reviewed your filing and have the following comment. 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 comment within ten business days by amending your filing, by providing the requested information , or advis e us as soon as possible when you will respond . If you do not believe our comment applies to your facts and circumstances, or do not believe an amendment is appropriate, please tell us why in your response.
After reviewing your response and any amendment you may file in response to this comment , we may have additional comments .
Form 20 -F for Fiscal Year Ended December 31, 2016
Financial Statements , page F -1
We note you present only two years of audited financial statements. Please amend your filing to include audited compa rative financial statements that cover the latest three fiscal years as required by Item 8.A.2 of Form 20 -F, and expand your Operating and Financial Review and Prospects disclosure in either Item 5 or Exhibit 19 accordingly. Please note that you may omit the balance sheet for the earliest of the three years in accordance with Instruction 1 to Item 8.A.2 of Form 20 -F, if that balance sheet is not required by a jurisdiction outside the United States. Please ensure to include an audit report (or series of audit reports) that covers all financial
Mr. Keith Morrison North American Nickel Inc. September 14, 2017 Page 2
statements and periods required to be presented. Refer to Item 8.A.2 and 3 of Form 20 -F and the related Instructions .
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 James Giugliano at (202) 551 -3319, or Angela Lumley at (202) 551 - 3398, with any questions.
Sincerely,
/s/ Rufus Decker
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Mail Stop 3561
September 14, 2017
Via E -mail
Mr. Keith Morrison
Chief Executive Officer
North American Nickel Inc.
1055 West Hastings Street
Suite 2200
Vancouver, British Columbia V6E 2E9
Canada
Re: North American Nickel Inc.
Form 20 -F for Fiscal Year Ended December 31, 2016
Filed April 24, 2017
File No. 000 -14740
Dear Mr. Morrison :
We have reviewed your filing and have the following comment. 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 comment within ten business days by amending your filing, by
providing the requested information , or advis e us as soon as possible when you will respond . If
you do not believe our comment applies to your facts and circumstances, or do not believe an
amendment is appropriate, please tell us why in your response.
After reviewing your response and any amendment you may file in response to this
comment , we may have additional comments .
Form 20 -F for Fiscal Year Ended December 31, 2016
Financial Statements , page F -1
We note you present only two years of audited financial statements. Please amend your filing to
include audited compa rative financial statements that cover the latest three fiscal years as
required by Item 8.A.2 of Form 20 -F, and expand your Operating and Financial Review and
Prospects disclosure in either Item 5 or Exhibit 19 accordingly. Please note that you may omit
the balance sheet for the earliest of the three years in accordance with Instruction 1 to Item 8.A.2
of Form 20 -F, if that balance sheet is not required by a jurisdiction outside the United States.
Please ensure to include an audit report (or series of audit reports) that covers all financial
Mr. Keith Morrison
North American Nickel Inc.
September 14, 2017
Page 2
statements and periods required to be presented. Refer to Item 8.A.2 and 3 of Form 20 -F and the
related Instructions .
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 James Giugliano at (202) 551 -3319, or Angela Lumley at (202) 551 -
3398, with any questions.
Sincerely,
/s/ Rufus Decker
Rufus Decker
Accounting Branch Chief
Office of Beverages, Apparel, and
Mining