SEC Comment Letter for NORDIC AMERICAN TANKERS Ltd (NAT) (CIK 0001000177) (NAT) — Jan 10, 2017
NORDIC AMERICAN TANKERS Ltd (NAT) (CIK 0001000177)
Date: Jan. 10, 2017 · CIK: 0001000177 · Accession: 0000000000-17-001009
AI Filing Summary & Sentiment
File numbers found in text: 001-13944
Referenced dates: December 23, 2016
Letter
Mail Stop 3561 January 10, 2017 Turid M. Sorensen Chief Financial Officer Nordic American Tankers Limited LOM Building 27 Reid Street Hamilton HM 11 Bermuda
Re: Nordic American Tankers Limited Form 20-F for the Year Ended December 31, 2015 Filed March 23, 2016 File No. 001-13944
Dear Ms. Sorensen :
We have reviewed your response letter dated December 23, 2016, 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 these comments within ten business days by providing the requested information or advise us as soon as possible when you will re spond. If you do not believe our comments apply to your facts and circumstances, please tell us why in your response.
After reviewing your response to these comments, we may have additional comments.
Form 6 -K furnished November 15, 2016
1. We have rev iewed your response to our prior comment 3 and refer you to Questions 102.07 and 102.10 of the Staff’s Compliance & Disclosure Interpretations (“C&DIs”) on Non-GAAP Financial Measures, issued on May 17, 2016. Specifically, free cash flow is typically a li quidity measure, which we would expect to be reconciled to cash flows from operating activities, rather than to net operating gain (loss), which you use in your reconciliation in your disclosure in the November 15, 2016 Form 6 -K. If you utilize this non-GAAP measure as a performance measure, please consider renaming the non -GAAP measure to more appropriately portray it as a performance measure. Please provide us with an example of the measure and the surrounding disclosure to be included in future filings . We may have further comment upon reviewing your response.
Turid M. Sorensen Nordic American Tankers Limited January 10, 2017 Page 2
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 Beverly Singleton at (202) 551 -3328 or Claire Erlanger at (202) 551 - 3301 if you have questions regarding comments on the financial statements and related matters. Please contact me at ( 202) 551 -3379 with any other questions.
Sincerely,
/s/ Melissa Raminpour
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Mail Stop 3561 January 10, 2017 Turid M. Sorensen Chief Financial Officer Nordic American Tankers Limited LOM Building 27 Reid Street Hamilton HM 11 Bermuda Re: Nordic American Tankers Limited Form 20-F for the Year Ended December 31, 2015 Filed March 23, 2016 File No. 001-13944 Dear Ms. Sorensen : We have reviewed your response letter dated December 23, 2016, 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 these comments within ten business days by providing the requested information or advise us as soon as possible when you will re spond. If you do not believe our comments apply to your facts and circumstances, please tell us why in your response. After reviewing your response to these comments, we may have additional comments. Form 6 -K furnished November 15, 2016 1. We have rev iewed your response to our prior comment 3 and refer you to Questions 102.07 and 102.10 of the Staff’s Compliance & Disclosure Interpretations (“C&DIs”) on Non-GAAP Financial Measures, issued on May 17, 2016. Specifically, free cash flow is typically a li quidity measure, which we would expect to be reconciled to cash flows from operating activities, rather than to net operating gain (loss), which you use in your reconciliation in your disclosure in the November 15, 2016 Form 6 -K. If you utilize this non-GAAP measure as a performance measure, please consider renaming the non -GAAP measure to more appropriately portray it as a performance measure. Please provide us with an example of the measure and the surrounding disclosure to be included in future filings . We may have further comment upon reviewing your response. Turid M. Sorensen Nordic American Tankers Limited January 10, 2017 Page 2 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 Beverly Singleton at (202) 551 -3328 or Claire Erlanger at (202) 551 - 3301 if you have questions regarding comments on the financial statements and related matters. Please contact me at ( 202) 551 -3379 with any other questions. Sincerely, /s/ Melissa Raminpour Melissa Raminpour Branch Chief Office of Tra nsportation and Leisure