SEC Comment Letter for NORDIC AMERICAN TANKERS Ltd (NAT) (CIK 0001000177) (NAT) — Feb 5, 2018
NORDIC AMERICAN TANKERS Ltd (NAT) (CIK 0001000177)
Date: Feb. 5, 2018 · CIK: 0001000177 · Accession: 0000000000-18-004057
AI Filing Summary & Sentiment
Letter
Mail Stop 3561 February 5, 2018 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 Fiscal Year Ended December 31, 2016 Filed May 1, 2017 File No. 001 -13944
Dear Mr. Sorensen :
We have reviewed your January 19, 2018 response to our comment letter and have the following comment s. 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 busine ss days by providing the requested information or advis e us as soon as possible when you will respond. 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. Unless we note otherwise, our references to prior comments are to comments in our December 15, 2017 letter .
Form 20 -F for Fiscal Year Ended December 31, 2016
H. — Critical Accounting Policies, page 39
Turid M. Sorensen Nordic American Tankers Limited February 5, 2018 Page 2
Goodwill, page 43
We reviewed your response to prior comment 5 and have the following comments/inquiries regarding your goodwill impairment model: Tell us how your TCE calculations translate into future cash flow projections. Tell us how many (annual) time periods are used for the discrete cash flow periods leading up to the terminal value. Tell us all of the assumptions used in your terminal value estimate (i.e. constant return on capital, constant growth rate and constant return on new investment capital). In estimating the WACC, tell us whether or not you considered adding a control prem ium when compiling the various factors included in the WACC calculation (e.g., cost of debt, market risk premium, unsystematic risk premium, beta, et al).
You may contact Jim Dunn at (202) 551 -3724 or me at (202) 551 -3379 if you have questions regarding comments on the financial statements and related matters. Please contact John Stickle at (202) 551 -3324 or John D. Brown at (202) 551 -3859 with any other questions.
Sincerely,
/s/ Melissa Raminpour
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Mail Stop 3561 February 5, 2018 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 Fiscal Year Ended December 31, 2016 Filed May 1, 2017 File No. 001 -13944 Dear Mr. Sorensen : We have reviewed your January 19, 2018 response to our comment letter and have the following comment s. 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 busine ss days by providing the requested information or advis e us as soon as possible when you will respond. 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. Unless we note otherwise, our references to prior comments are to comments in our December 15, 2017 letter . Form 20 -F for Fiscal Year Ended December 31, 2016 H. — Critical Accounting Policies, page 39 Turid M. Sorensen Nordic American Tankers Limited February 5, 2018 Page 2 Goodwill, page 43 We reviewed your response to prior comment 5 and have the following comments/inquiries regarding your goodwill impairment model: Tell us how your TCE calculations translate into future cash flow projections. Tell us how many (annual) time periods are used for the discrete cash flow periods leading up to the terminal value. Tell us all of the assumptions used in your terminal value estimate (i.e. constant return on capital, constant growth rate and constant return on new investment capital). In estimating the WACC, tell us whether or not you considered adding a control prem ium when compiling the various factors included in the WACC calculation (e.g., cost of debt, market risk premium, unsystematic risk premium, beta, et al). You may contact Jim Dunn at (202) 551 -3724 or me at (202) 551 -3379 if you have questions regarding comments on the financial statements and related matters. Please contact John Stickle at (202) 551 -3324 or John D. Brown at (202) 551 -3859 with any other questions. Sincerely, /s/ Melissa Raminpour Melissa Raminpour Branch Chief Office of Transportation and Leisure