SEC Comment Letter for EVOLUTION PETROLEUM CORP (EPM) (CIK 0001006655) (EPM) — Apr 6, 2016
EVOLUTION PETROLEUM CORP (EPM) (CIK 0001006655)
Date: April 6, 2016 · CIK: 0001006655 · Accession: 0000000000-16-071194
AI Filing Summary & Sentiment
Reasoning
Referenced dates: March 10, 2016
Letter
Mail Stop 4628 April 6, 2016 Via E -Mail David Joe Chief Financial Officer and Senior Vice President Evolution Petroleum Corporation 2500 City West Blvd., Suite 1300 Houston, Texas 77042
Re: Evolution Petroleum Corporation Form 10-K for the Fiscal Year ended June 30, 2015 Response dated March 23, 2016 File No. 1 -32942
Dear Mr. Joe :
We have reviewed your March 23, 2016 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 possibl e 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 March 10, 2016 letter .
Form 10 -K for the Fiscal Year ended June 30, 2015
Properties, page 15
Proved Undeveloped Reserves, page 18
1. We note the proposed expanded disclosure provided in your response to comment 5 in our letter dated March 10, 2016 regarding the conversion of unproved reserves to proved reserves during fiscal 2015. Please expand the disclosure to also include a statement regarding the conversion of your proved undeveloped reserves to p roved developed reserves, to comply with Item 1203(b) of Regulation S -K.
David Joe Evolution Petroleum Corporation April 6, 2016 Page 2
Acreage Data, page 20
2. We have read the explanation provided in your response to comment 7 indicating the Delhi Field is unitized and consequently, all acreage in the unit is held by production. Please note the undrilled acreage within a unit that is held by production sho uld be reported as undeveloped acreage for purposes of disclosure under Item 1208(b) of Regulation S -K. Please modify your disclosure as necessary to resolve any inconsistencies in the classification of your acreage.
You may contact John Hodgin, Petrole um Engineer, at (202) 551 -3699 if you have questions regarding the comment s. Please contact me at (202) 551 -3686 with any other questions.
Sincerely,
/s/ Karl Hiller
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Mail Stop 4628 April 6, 2016 Via E -Mail David Joe Chief Financial Officer and Senior Vice President Evolution Petroleum Corporation 2500 City West Blvd., Suite 1300 Houston, Texas 77042 Re: Evolution Petroleum Corporation Form 10-K for the Fiscal Year ended June 30, 2015 Response dated March 23, 2016 File No. 1 -32942 Dear Mr. Joe : We have reviewed your March 23, 2016 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 possibl e 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 March 10, 2016 letter . Form 10 -K for the Fiscal Year ended June 30, 2015 Properties, page 15 Proved Undeveloped Reserves, page 18 1. We note the proposed expanded disclosure provided in your response to comment 5 in our letter dated March 10, 2016 regarding the conversion of unproved reserves to proved reserves during fiscal 2015. Please expand the disclosure to also include a statement regarding the conversion of your proved undeveloped reserves to p roved developed reserves, to comply with Item 1203(b) of Regulation S -K. David Joe Evolution Petroleum Corporation April 6, 2016 Page 2 Acreage Data, page 20 2. We have read the explanation provided in your response to comment 7 indicating the Delhi Field is unitized and consequently, all acreage in the unit is held by production. Please note the undrilled acreage within a unit that is held by production sho uld be reported as undeveloped acreage for purposes of disclosure under Item 1208(b) of Regulation S -K. Please modify your disclosure as necessary to resolve any inconsistencies in the classification of your acreage. You may contact John Hodgin, Petrole um Engineer, at (202) 551 -3699 if you have questions regarding the comment s. Please contact me at (202) 551 -3686 with any other questions. Sincerely, /s/ Karl Hiller Karl Hiller Branch Chief Office of Natural Resources