SEC Comment Letter for GRUPO SIMEC, S.A.B. de C.V. (SIM) (CIK 0000887153) (SIM) — Oct 24, 2013
GRUPO SIMEC, S.A.B. de C.V. (SIM) (CIK 0000887153)
Date: Oct. 24, 2013 · CIK: 0000887153 · Accession: 0000000000-13-058450
AI Filing Summary & Sentiment
Reasoning
Referenced dates: August 19, 2013
Letter
October 24 , 2013 Via E -mail Mr. Mario Moreno Cortez, Coordinator of Finance Group Simec Calzada Lázaro Cárdenas 601 Colonia La Nogalera, Guadalajara Jalisco, México 44440
Re: Group Simec Form 20-F for the year ended December 31, 2012 Filed May 15, 2013 File No. 1 -11176
Dear Mr. Cortez :
We have reviewed your response to our comment letter dated August 19, 2013 and have the following comment. In our comment, 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 providing the requested information, or by advising us when you will provide the requested response. If you do not believe our comment appl ies to your facts and circumstances please tell us why in your response.
After reviewing the information you provide in response to this comment, we may have additional comments.
26. Contingencies, page F -45
Department of Toxic Substances Control, DTSC, page F -45
1. We have read your response to prior comment eight of our letter dated August 19, 2013. Please revise future disclosures to: quantify the penalties recommended by the technical division of the DTSC; quantify any a mount accrued and/or explain why amounts have not been accrued; and update the status of your communications with DTSC, including when you expect this matter to be resolved.
Mr. Mario Moreno Cortez Group Simec October 24 , 2013 Page 2
You may contact Mindy Hooker at (202) 551 -3732 or Anne McConnell at (202) 551 - 3709 if you have questions regarding comments on the financial statements and related matters. Please contact me at (202) 551 -3768 with any other questions.
Sincerely,
/s/ John Cash
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October 24 , 2013 Via E -mail Mr. Mario Moreno Cortez, Coordinator of Finance Group Simec Calzada Lázaro Cárdenas 601 Colonia La Nogalera, Guadalajara Jalisco, México 44440 Re: Group Simec Form 20-F for the year ended December 31, 2012 Filed May 15, 2013 File No. 1 -11176 Dear Mr. Cortez : We have reviewed your response to our comment letter dated August 19, 2013 and have the following comment. In our comment, 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 providing the requested information, or by advising us when you will provide the requested response. If you do not believe our comment appl ies to your facts and circumstances please tell us why in your response. After reviewing the information you provide in response to this comment, we may have additional comments. 26. Contingencies, page F -45 Department of Toxic Substances Control, DTSC, page F -45 1. We have read your response to prior comment eight of our letter dated August 19, 2013. Please revise future disclosures to: quantify the penalties recommended by the technical division of the DTSC; quantify any a mount accrued and/or explain why amounts have not been accrued; and update the status of your communications with DTSC, including when you expect this matter to be resolved. Mr. Mario Moreno Cortez Group Simec October 24 , 2013 Page 2 You may contact Mindy Hooker at (202) 551 -3732 or Anne McConnell at (202) 551 - 3709 if you have questions regarding comments on the financial statements and related matters. Please contact me at (202) 551 -3768 with any other questions. Sincerely, /s/ John Cash John Cash Branch Chief