SEC Comment Letter for METHANEX CORP (MEOH) (CIK 0000886977) (MEOH) — Mar 19, 2020
METHANEX CORP (MEOH) (CIK 0000886977)
Date: March 19, 2020 · CIK: 0000886977 · Accession: 0000000000-20-002428
AI Filing Summary & Sentiment
File numbers found in text: 000-20115
Letter
March 18, 2020 Ian Cameron Chief Financial Officer METHANEX CORP 1800 Waterfront Centre 200 Burrard Street Vancouver, British Columbia Canada V6C 3M1 Re:METHANEX CORP Form 40-F for Fiscal Year Ended December 31, 2018 Filed March 12, 2019 File No. 000-20115 Response Dated March 13, 2020 Dear Mr. Cameron: We have reviewed your March 13, 2020 response to our comment letter 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 Fiscal Year Ended December 31, 2018 2. Significant accounting policies n) Revenue Recognition, page 56 1.Based on the information provided in your correspondence dated December 3, 2019 and January 21, 2020 and a telephone conversation on February 19, 2020, we believe your conclusion that you are acting as an agent for the sale of Atlas’ methanol and the resulting recognition of revenue on a net basis is inconsistent with the guidance in IFRS 15.33 and IFRS 15.B37. In this regard, we believe you obtain control of the methanol produced at the Atlas facility before that methanol is transferred to the customer. Please restate your financial statements to recognize revenue for the sale of the methanol produced by Atlas on a gross basis. Please also reconsider management’s assessment of the effectiveness of internal controls over financial reporting and disclosure controls and procedures in light of the restatement. You may contact Tracey Houser, Staff Accountant, at (202) 551-3736, or Terence
FirstName LastNameIan Cameron Comapany NameMETHANEX CORP March 18, 2020 Page 2 FirstName LastName Ian Cameron METHANEX CORP March 18, 2020 Page 2 O’Brien, Accounting Branch Chief, at (202) 551-3355, if you have questions regarding comments on the financial statements and related matters. Sincerely, Division of Corporation Finance Office of Life Sciences cc: Kevin Price
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March 18, 2020
Ian Cameron
Chief Financial Officer
METHANEX CORP
1800 Waterfront Centre
200 Burrard Street
Vancouver, British Columbia
Canada V6C 3M1
Re:METHANEX CORP
Form 40-F for Fiscal Year Ended December 31, 2018
Filed March 12, 2019
File No. 000-20115
Response Dated March 13, 2020
Dear Mr. Cameron:
We have reviewed your March 13, 2020 response to our comment letter 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 Fiscal Year Ended December 31, 2018
2. Significant accounting policies
n) Revenue Recognition, page 56
1.Based on the information provided in your correspondence dated December 3, 2019 and
January 21, 2020 and a telephone conversation on February 19, 2020, we believe your
conclusion that you are acting as an agent for the sale of Atlas’ methanol and the resulting
recognition of revenue on a net basis is inconsistent with the guidance in IFRS 15.33 and
IFRS 15.B37. In this regard, we believe you obtain control of the methanol produced at
the Atlas facility before that methanol is transferred to the customer. Please restate your
financial statements to recognize revenue for the sale of the methanol produced by Atlas
on a gross basis. Please also reconsider management’s assessment of the effectiveness of
internal controls over financial reporting and disclosure controls and procedures in light of
the restatement.
You may contact Tracey Houser, Staff Accountant, at (202) 551-3736, or Terence
FirstName LastNameIan Cameron
Comapany NameMETHANEX CORP
March 18, 2020 Page 2
FirstName LastName
Ian Cameron
METHANEX CORP
March 18, 2020
Page 2
O’Brien, Accounting Branch Chief, at (202) 551-3355, if you have questions regarding
comments on the financial statements and related matters.
Sincerely,
Division of Corporation Finance
Office of Life Sciences
cc: Kevin Price