SEC Comment Letter for RUBICON MINERALS CORP (CIK 0001057791) — Sep 9, 2005
RUBICON MINERALS CORP (CIK 0001057791)
Date: Sept. 9, 2005 · CIK: 0001057791 · Accession: 0000000000-05-046644
AI Filing Summary & Sentiment
File numbers found in text: 001-31345
Referenced dates: August 12, 2005, August 12, 2005
Letter
September 9, 2005 Mr. David A. Adamson President and Chief Executive Officer Rubicon Minerals Corporation 1540-800 West Pender Street Vancouver, British Columbia V6C 2V6 Canada
Re: Rubicon Minerals Corporation Form 20-F for the Year Ended December 31, 2004 Filed March 15, 2005 File No. 001-31345 Supplemental Response dated August 29, 2005
Dear Mr. Adamson:
We have reviewed your filings and have the following comments. We have limited our review of your filings to those issues we have addressed in our comments. Where indicated, we think you should revise your document in response to these comments. If you disagree, we will consider your explanation as to why our comment is inapplicable or a revision is unnecessary. In some of our comments, we may ask you to provide us with information so we may better understand your disclosure. After reviewing this information, we may raise additional comments. The page numbers referenced below correspond to those utilized in the Form 20-F.
Accounting Comment
Form 20-F for the Year Ended December 31, 2004
Consolidated Financial Statements, page 65
Differences between Canadian and United States Generally Accepted Accounting Principles, page 86
1. We note your response to the prior comment number one from our letter dated August 12, 2005, in which you state that the company recognized an impairment loss, consistent with FASB Statement No. as it could not substantiate and quantify the assets` undiscounted cash flows. Based on your circumstances, it appears you should have recognized a similar impairment loss under Canadian GAAP. Please tell us why you did not recognize any impairment loss under Canadian GAAP. Include in your explanation the specific accounting literature that supports your position, and explain how that guidance differs from FASB Statement No. 144.
Engineering Comment
Form 20-F for the Year Ended December 31, 2004
Goldcorp Option Agreement, page 23
2. We re-issue the comment number three from our letter dated August 12, 2005. The example cited was corrected, however the filing may not have been reviewed completely to be in compliance with the sample result guidelines. Another example of selective high-grade disclosure may be found on page 27, the sixth paragraph which states "the regional potential of the area has been recently underscored by the discovery of the Snow White, Linda and Broken Hose veins at South Golden Promise by Crosshair Exploration and Mining Ltd., where quartz veins assay up to 105 g/t au." Revise the entire filing to conform to the sampling guidelines.
Closing Comments
Please respond to these comments within 10 business days or tell us when you will provide us with a response. Please furnish a letter that keys your responses to our comments and provides any requested information. Detailed letters greatly facilitate our review. Please understand that we may have additional comments after reviewing your responses to our comments. You may contact Yong Choi at (202) 551-3758, or April Sifford, Branch Chief, at (202) 551-3684 if you have questions regarding comments on the financial statements and related matters. You may contact Ken Schuler, Mining Engineer, at (202) 551-3718 with questions about engineering comments. Please contact me at (202) 551-3740 with any other questions.
Sincerely,
H. Roger Schwall
Assistant Director
Show Raw Text
<DOCUMENT>
<TYPE>LETTER
<SEQUENCE>1
<FILENAME>filename1.txt
<TEXT>
September 9, 2005
Mr. David A. Adamson
President and Chief Executive Officer
Rubicon Minerals Corporation
1540-800 West Pender Street
Vancouver, British Columbia V6C 2V6
Canada
Re: Rubicon Minerals Corporation
Form 20-F for the Year Ended December 31, 2004
Filed March 15, 2005
File No. 001-31345
Supplemental Response dated August 29, 2005
Dear Mr. Adamson:
We have reviewed your filings and have the following
comments.
We have limited our review of your filings to those issues we have
addressed in our comments. Where indicated, we think you should
revise your document in response to these comments. If you
disagree,
we will consider your explanation as to why our comment is
inapplicable or a revision is unnecessary. In some of our
comments, we
may ask you to provide us with information so we may better
understand
your disclosure. After reviewing this information, we may raise
additional comments. The page numbers referenced below correspond
to
those utilized in the Form 20-F.
Accounting Comment
Form 20-F for the Year Ended December 31, 2004
Consolidated Financial Statements, page 65
Differences between Canadian and United States Generally Accepted
Accounting Principles, page 86
1. We note your response to the prior comment number one from our
letter dated August 12, 2005, in which you state that the company
recognized an impairment loss, consistent with FASB Statement No.
144
as it could not substantiate and quantify the assets` undiscounted
cash flows. Based on your circumstances, it appears you should
have
recognized a similar impairment loss under Canadian GAAP. Please
tell
us why you did not recognize any impairment loss under Canadian
GAAP.
Include in your explanation the specific accounting literature
that
supports your position, and explain how that guidance differs from
FASB Statement No. 144.
Engineering Comment
Form 20-F for the Year Ended December 31, 2004
Goldcorp Option Agreement, page 23
2. We re-issue the comment number three from our letter dated
August
12, 2005. The example cited was corrected, however the filing may
not
have been reviewed completely to be in compliance with the sample
result guidelines. Another example of selective high-grade
disclosure
may be found on page 27, the sixth paragraph which states "the
regional potential of the area has been recently underscored by
the
discovery of the Snow White, Linda and Broken Hose veins at South
Golden Promise by Crosshair Exploration and Mining Ltd., where
quartz
veins assay up to 105 g/t au." Revise the entire filing to
conform to
the sampling guidelines.
Closing Comments
Please respond to these comments within 10 business days or
tell
us when you will provide us with a response. Please furnish a
letter
that keys your responses to our comments and provides any
requested
information. Detailed letters greatly facilitate our review.
Please
understand that we may have additional comments after reviewing
your
responses to our comments.
You may contact Yong Choi at (202) 551-3758, or April
Sifford,
Branch Chief, at (202) 551-3684 if you have questions regarding
comments on the financial statements and related matters. You may
contact Ken Schuler, Mining Engineer, at (202) 551-3718 with
questions
about engineering comments. Please contact me at (202) 551-3740
with
any other questions.
Sincerely,
H. Roger Schwall
Assistant Director
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Mr. Adamson
Rubicon Minerals Corporation
September 9, 2005
Page 1
UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-7010
DIVISION OF
CORPORATION FINANCE
MAIL STOP 7010
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