SEC Comment Letter for NORDIC AMERICAN TANKERS Ltd (NAT) (CIK 0001000177) (NAT) — Mar 19, 2018
NORDIC AMERICAN TANKERS Ltd (NAT) (CIK 0001000177)
Date: March 19, 2018 · CIK: 0001000177 · Accession: 0000000000-18-008366
AI Filing Summary & Sentiment
Letter
Mail Stop 3561 March 19, 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 March 2 , 2018 response to our comment letter 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 comment 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 belie ve our comment appl ies to your facts and circumstances, please tell us why in your response.
After reviewing your response to this comment, we may have additional comments. Unless we note otherwise, our references to prior comments are to comments in o ur December 15, 2017 letter .
Exhibits, page 71
1. We note your response to our prior comment 6. Please provide us further analysis as to why you believe this contract is the type that ordinarily accompanies the kind of business you conduct. Address for example that you have one substantial credit facility whereas other shipping companies often have multiple smaller vessel -specific credit facilities. As an alternative , please file as an exhibit the revolving credit facility referenced on pages 37 and F-21, or confirm that you will file the revolving credit facility as an exhibit with your Annual Report on Form 20 -F for the year ended 2017.
Turid M. Sorensen Nordic American Tankers Limited March 19 , 2018 Page 2
You may contact Jim Dunn at (202) 551 -3724 or me at (202) 551 -3379 if you have questions regarding comments on t he 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 March 19, 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 March 2 , 2018 response to our comment letter 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 comment 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 belie ve our comment appl ies to your facts and circumstances, please tell us why in your response. After reviewing your response to this comment, we may have additional comments. Unless we note otherwise, our references to prior comments are to comments in o ur December 15, 2017 letter . Exhibits, page 71 1. We note your response to our prior comment 6. Please provide us further analysis as to why you believe this contract is the type that ordinarily accompanies the kind of business you conduct. Address for example that you have one substantial credit facility whereas other shipping companies often have multiple smaller vessel -specific credit facilities. As an alternative , please file as an exhibit the revolving credit facility referenced on pages 37 and F-21, or confirm that you will file the revolving credit facility as an exhibit with your Annual Report on Form 20 -F for the year ended 2017. Turid M. Sorensen Nordic American Tankers Limited March 19 , 2018 Page 2 You may contact Jim Dunn at (202) 551 -3724 or me at (202) 551 -3379 if you have questions regarding comments on t he 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