SEC Comment Letter for CNX Resources Corp (CNX) (CIK 0001070412) (CNX) — Mar 29, 2021
CNX Resources Corp (CNX) (CIK 0001070412)
Date: March 29, 2021 · CIK: 0001070412 · Accession: 0000000000-21-003735
AI Filing Summary & Sentiment
File numbers found in text: 001-14901
Letter
United States securities and exchange commission logo March 29, 2021 Donald W. Rush Chief Financial Officer CNX Resources Corporation 1000 CONSOL Energy Drive Suite 400 Canonsburg, PA 15317-6506 Re:CNX Resources Corporation Form 10-K for the Year Ended December 31, 2020 Filed on February 9, 2021 File No. 001-14901 Dear Mr. Rush: 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 10-K for the Year Ended December 31, 2020 Management's Discussion and Analysis of Financial Condition and Results of Operations Results of Operations: Year Ended December 31, 2020 Compared with the Year Ended December 31, 2019 Selected Operating Revenue and Other Cost Data, page 45 1.We note your disclosure of total revenue, average costs and average margin in presenting information about your production operations in the table under this heading. Please tell us how you considered these measures as non-GAAP measures under Item 10(e) of Regulation S-K. To the extent you identify these as non-GAAP measures, please provide the appropriate disclosures that comply with this guidance. 2.We note your presentation of "total revenue" excludes various amounts accounted for as revenue under GAAP. Please tell us how your labelling of this measure as "total
FirstName LastNameDonald W. Rush Comapany NameCNX Resources Corporation March 29, 2021 Page 2 FirstName LastName Donald W. Rush CNX Resources Corporation March 29, 2021 Page 2 revenues" complies with Item 10(e)(1)(ii)(E) of Regulation S-K, which precludes using labels for non-GAAP metrics "...that are the same as, or confusingly similar to, titles or descriptions used for GAAP financial measures" or revise your disclosure accordingly. 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. You may contact Brian McAllister, Staff Accountant, at (202) 551-3341 or Craig Arakawa, Accounting Branch Chief, at (202) 551-3560 if you have questions regarding comments on the financial statements and related matters. Sincerely, Division of Corporation Finance Office of Energy & Transportation
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United States securities and exchange commission logo
March 29, 2021
Donald W. Rush
Chief Financial Officer
CNX Resources Corporation
1000 CONSOL Energy Drive
Suite 400
Canonsburg, PA 15317-6506
Re:CNX Resources Corporation
Form 10-K for the Year Ended December 31, 2020
Filed on February 9, 2021
File No. 001-14901
Dear Mr. Rush:
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 10-K for the Year Ended December 31, 2020
Management's Discussion and Analysis of Financial Condition and Results of Operations
Results of Operations: Year Ended December 31, 2020 Compared with the Year Ended
December 31, 2019
Selected Operating Revenue and Other Cost Data, page 45
1.We note your disclosure of total revenue, average costs and average margin in presenting
information about your production operations in the table under this heading. Please tell
us how you considered these measures as non-GAAP measures under Item 10(e) of
Regulation S-K. To the extent you identify these as non-GAAP measures, please provide
the appropriate disclosures that comply with this guidance.
2.We note your presentation of "total revenue" excludes various amounts accounted for as
revenue under GAAP. Please tell us how your labelling of this measure as "total
FirstName LastNameDonald W. Rush
Comapany NameCNX Resources Corporation
March 29, 2021 Page 2
FirstName LastName
Donald W. Rush
CNX Resources Corporation
March 29, 2021
Page 2
revenues" complies with Item 10(e)(1)(ii)(E) of Regulation S-K, which precludes using
labels for non-GAAP metrics "...that are the same as, or confusingly similar to, titles or
descriptions used for GAAP financial measures" or revise your disclosure accordingly.
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.
You may contact Brian McAllister, Staff Accountant, at (202) 551-3341 or Craig
Arakawa, Accounting Branch Chief, at (202) 551-3560 if you have questions regarding
comments on the financial statements and related matters.
Sincerely,
Division of Corporation Finance
Office of Energy & Transportation