SEC Comment Letter 0000000000-23-008410 to ALMADEN MINERALS LTD (AAUAF) (CIK 0001015647) (AAUAF)
ALMADEN MINERALS LTD (AAUAF) (CIK 0001015647)
Date: Aug. 4, 2023 · CIK: 0001015647 · Accession: 0000000000-23-008410
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File numbers found in text: 001-32702
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United States securities and exchange commission logo
August 4, 2023
Korm Trieu
Chief Financial Officer & Corporate Secretary
ALMADEN MINERALS LTD
1333 Johnston Street, #210
Vancouver, British Columbia Canada V6H 3R9
Re:ALMADEN MINERALS LTD
Form 20-F for the fiscal year ended December 31, 2022
Filed April 27, 2023
File No. 001-32702
Dear Korm Trieu:
We have reviewed your filing 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 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.
Form 20-F
Location and Access, page 29
1.Please modify your filing and locate your property within one-mile using an easily
recognizable coordinate system as required by Item 1304(b)(1)(i) of Regulation S-K.
History of Past Work, page 33
2.Please modify your filing and disclose the book value of your mining property as required
by Item 1304(d)(2)(iii) of Regulation S-K.
Mineral Resource Estimate, page 38
3.We note your disclosure of resources inclusive of reserves in your filing. Please modify
your filing and remove your inclusive resource tabulation and replace it with a tabulation
of resources exclusive of reserves as required by Item 1304(d)(2) of Regulation S-K.
FirstName LastNameKorm Trieu
Comapany NameALMADEN MINERALS LTD
August 4, 2023 Page 2
FirstName LastNameKorm Trieu
ALMADEN MINERALS LTD
August 4, 2023
Page 2
Exhibit 14.2
Metallurgical Performance Projections, page E-176
4.Please modify your filing and disclose the Qualified Person’s opinion on the adequacy of
the metallurgical process test data and conclusions. See Item 601(b)(96)(iii)(B)(10)(v) of
Regulation S-K.
Exhibit 14.2
Classification, page E-194
5.Please modify your filing and disclose your resources exclusive of reserves as required by
Item 601(b)(96)(iii)(B)(11)(ii) of Regulation S-K.
6.Please modify your filing and disclose the Qualified Person’s opinion on whether all
issues related to technical and/or economic factors influencing economic extraction can be
resolved with further work. See Item 601(b)(96)(iii)(B)(11)(vii) of Regulation S-K.
Exhibit 14.2
Mineral Reserves, page E-202
7.Please modify your filing and disclose the Qualified Person’s opinion on risk factors and
their effect on reserve estimates through changes to the modifying factors. See Item
601(b)(96)(iii)(B)(12)(vi) of Regulation S-K.
Exhibit 14.2
Monitoring, page E-280
8.Please modify your filing and disclose the Qualified Person’s opinion on the adequacy of
the current plans to address issues related to environmental compliance, permitting, or
local individuals and/or groups. See Item 601(b)(96)(iii)(B)(17)(vi) of Regulation S-K.
Exhibit 14.2
Analysis, page E-293
9.Please review your Cash Flow Summary found in Table 19.2 as it relates to your Capital
and Operating Costs outlined in Section 18. Sustaining Capital does not appear to
correspond to the text and Closure Costs do not appear to be included in your tabulation.
In addition, please review the annual Mine Operating Costs and Tax Calculations and
provide additional detail in your text regarding their calculation. See Item
601(b)(96)(iii)(B)(19)(i) of Regulation S-K.
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.
FirstName LastNameKorm Trieu
Comapany NameALMADEN MINERALS LTD
August 4, 2023 Page 3
FirstName LastName
Korm Trieu
ALMADEN MINERALS LTD
August 4, 2023
Page 3
Please direct any questions to George K. Schuler at 202-551-3718 if you have
questions regarding the engineering comments or Craig Arakawa at at 202-551-3650 with any
other questions.
Sincerely,
Division of Corporation Finance
Office of Energy & Transportation