SEC Company Response from RUBICON MINERALS CORP (CIK 0001057791) — Dec 22, 2005

RUBICON MINERALS CORP (CIK 0001057791)
Date: Dec. 22, 2005 · CIK: 0001057791 · Accession: 0000912282-05-000980

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Date

December 22, 2005

Author

Not clearly detected

Form

CORRESP

Company

RUBICON MINERALS CORP (CIK 0001057791)

Letter

86 Trinity Place New York, New York 10006 Response to SEC Comment

Re:

Dear Mr. Choi;

Pursuant to our conversation, we have reviewed EITF 04-2 and note the following:

In paragraph 11. of the Minutes, titled Transition, the Task Force states:

“this issue is effective for the first reporting period beginning after the Board ratification of the consensus becomes effective (refer to paragraph 12). Prior period amounts should be reclassified to conform to the requirements of this consensus. Any effects on the amortization or depreciation of mineral rights should be accounted for prospectively.” [paragraph 12 indicates that the effective date had not been finalized at that time]

The FASB website, in the EITF section under “Effective dates of recent FASB pronouncements”, states that EITF 04-2 is effective for reporting periods beginning after April 29, 2004.

Rubicon Minerals Corporation is a foreign private issuer and is required to file its annual reports on Form 20-F, due six (6) months after its financial year end, December 31. EITF 04-2 is effective for reporting periods beginning after April 29, 2004 or for Rubicon Minerals Corporation, beginning in its financial year beginning January 1, 2005.

Accordingly, Rubicon Minerals Corporation will adopt the changes recommended by EITF 04-2, effective January 1, 2005. Rubicon Minerals Corporation’s financial statements included in its annual report for the year ending December 31, 2005 will reflect the changes to its accounting policies in accordance with EITF 04-2.

Yours truly,

Rubicon Minerals Corp.

/s/ Robert Lewis

Robert Lewis

Chief Financial Officer

cc:

Kenneth Sam, Dorsey & Whitney LLP

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CORRESP
1
filename1.htm

December 22, 2005

American Stock Exchange

86 Trinity Place

New York, New York    10006

Re:

Response to SEC Comment

Dear Mr. Choi;

        Pursuant
to our conversation, we have reviewed EITF 04-2 and note the following:

In
paragraph 11. of the Minutes, titled Transition, the Task Force states:

        “this
issue is effective for the first reporting period beginning after the Board ratification
of the consensus becomes  effective (refer to paragraph 12). Prior period amounts
should be reclassified to conform to the requirements of this  consensus. Any
effects on the amortization or depreciation of mineral rights should be accounted for
prospectively.” [paragraph 12 indicates that the effective date had not been
finalized at that time]

        The
FASB website, in the EITF section under “Effective dates of recent FASB
pronouncements”, states that EITF 04-2 is effective for reporting periods beginning
after April 29, 2004.

        Rubicon
Minerals Corporation is a foreign private issuer and is required to file its annual
reports on Form 20-F, due six (6) months after its financial year end, December 31. EITF
04-2 is effective for reporting periods beginning after April 29, 2004 or for Rubicon
Minerals Corporation, beginning in its financial year beginning January 1, 2005.

        Accordingly,
Rubicon Minerals Corporation will adopt the changes recommended by EITF 04-2, effective
January 1, 2005. Rubicon Minerals Corporation’s financial statements included in its
annual report for the year ending December 31, 2005 will reflect the changes to its
accounting policies in accordance with EITF 04-2.

     Yours truly,

     Rubicon Minerals Corp.

/s/ Robert Lewis

     Robert Lewis

     Chief Financial Officer

cc:

Kenneth
Sam, Dorsey & Whitney LLP

SecProbe.io