SEC Company Response from SOLITARIO RESOURCES CORP. (XPL) (CIK 0000917225) (XPL) — Feb 11, 2010
SOLITARIO RESOURCES CORP. (XPL) (CIK 0000917225)
Date: Feb. 11, 2010 · CIK: 0000917225 · Accession: 0000917225-10-000003
AI Filing Summary & Sentiment
Reasoning
Referenced dates: November 9, 2009
Letter
RESP22
February 2, 2010
Gary Newberry
Securities and Exchange Commission
Division of Corporate Finance
100 F Street NE
Washington, DC 20549-4628
Via facsimile to (703)-813-6982
Re: Solitario Exploration & Royalty Corp.
Mr. Newberry:
In response to the phone conversation held on January 26, 2010, we are enclosing proposed journal entries to our 2007-2008 and quarterly 2009 financial statements which we believe reflect the position of the staff of the Securities and Exchange Commission ("Staff") on the treatment of equity contributions by Anglo Platinum to our subsidiary, Pedra Branca Mineracao, Ltd. as described in your comment letter dated November 9, 2009.
We have also enclosed details summarizing the changes the journal entries would have to Solitario's existing accounts. Finally we have presented unaudited draft financial statement pages to assist the Staff in analyzing the effects on our reported numbers.
We will be presenting this same information to Solitario's Audit Committee of the Board of Directors later this week. The Audit Committee will evaluate such proposed changes for materiality in accordance with SAB 99 and whether such changes, if deemed appropriate, necessitate restatement of our financial statements as the correction of an error or as a change in accounting principle from one acceptable method to another.
Please note the attached information does not include additional disclosures required in our periodic reports regarding the reasons for the change or disclosures which clarify that the deferred noncontrolling shareholder payment account will not be settled in cash, refunded to Anglo Platinum, or constitute a contractual obligation.
If you have any questions regarding this response letter, please contact either Christopher E. Herald or me at Solitario at (303) 534-1030.
Sincerely
/s/ James R. Maronick
Show Raw Text
CORRESP
1
filename1.htm
RESP22
February 2, 2010
Gary Newberry
Securities and Exchange Commission
Division of Corporate Finance
100 F Street NE
Washington, DC 20549-4628
Via facsimile to (703)-813-6982
Re: Solitario Exploration & Royalty Corp.
Mr. Newberry:
In response to the phone conversation held on January 26, 2010, we are enclosing proposed journal entries to our 2007-2008 and quarterly 2009 financial statements which we believe reflect the position of the staff of the Securities and Exchange Commission ("Staff") on the treatment of equity contributions by Anglo Platinum to our subsidiary, Pedra Branca Mineracao, Ltd. as described in your comment letter dated November 9, 2009.
We have also enclosed details summarizing the changes the journal entries would have to Solitario's existing accounts. Finally we have presented unaudited draft financial statement pages to assist the Staff in analyzing the effects on our reported numbers.
We will be presenting this same information to Solitario's Audit Committee of the Board of Directors later this week. The Audit Committee will evaluate such proposed changes for materiality in accordance with SAB 99 and whether such changes, if deemed appropriate, necessitate restatement of our financial statements as the correction of an error or as a change in accounting principle from one acceptable method to another.
Please note the attached information does not include additional disclosures required in our periodic reports regarding the reasons for the change or disclosures which clarify that the deferred noncontrolling shareholder payment account will not be settled in cash, refunded to Anglo Platinum, or constitute a contractual obligation.
If you have any questions regarding this response letter, please contact either Christopher E. Herald or me at Solitario at (303) 534-1030.
Sincerely
/s/ James R. Maronick
CFO
Solitario Exploration & Royalty Corp.
Enclosed
1
<PAGE>
2
<PAGE>
3
<PAGE>
4
<PAGE>
5
<PAGE>
6
<PAGE>
7
<PAGE>
8
<PAGE>
9
<PAGE>
10
<PAGE>
11