SEC Comment Letter for ALLIANCE RESOURCE PARTNERS LP (ARLP) (CIK 0001086600) (ARLP) — Dec 22, 2015
ALLIANCE RESOURCE PARTNERS LP (ARLP) (CIK 0001086600)
Date: Dec. 22, 2015 · CIK: 0001086600 · Accession: 0000000000-15-058999
AI Filing Summary & Sentiment
Reasoning
Letter
Mail Stop 3561 December 2 2, 2015 Via E -mail Mr. Brian L. Cantrell Chief Financial Officer Alliance Resource Partners, L.P. 1717 South Boulder Avenue Suite 400 Tulsa, O K 74119
Re: Alliance Resource Partners, L.P. Form 10-K for the Year Ended December 31, 2014 Filed February 27, 2015 Response Dated December 3, 2015 File 0 -26823
Dear Mr. Cantrell :
We have reviewed your December 3, 2015 response to our comment letter 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 busine ss days by providing the requested information or advis e 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. Unless we no te otherwise, our references to our prior comments are to comments in our November 3, 2015 letter.
Form 10 -K for the Year Ended December 31, 2014
Consolidated Financial Statements Note 1. Organization and Presentation Organization, page 79
1. Your response to comment 2 and your proposed disclosures with respect to both the Intermediate Partnership and Alliance Coal, LLC indicate that you are consolidating each of these entities because you or the Intermediate Partnership are the primary benefic iaries of these entities. Given this factor and the significance of these entities to your consolidated financial statements, please revise future filings to include all of the
Mr. Brian L. Cantrell Alliance Resource Partners, L.P. December 2 2, 2015 Page 2
disclosures outlined in ASC 810 -10-50-2AA, 810 -10-50-3, and ASC 810 -50-5A, as applicable. Please provide us your proposed disclosures. If you believe certain disclosures outlined in the ASC guidance noted above are not applicable, please also explain to us the basis for those conclusions.
You may contact Linda Cvrkel at (202) 551-3813 or Rufus Decker, Accounting Branch Chief , at (202) 551-3769 with any questions regarding comments on your financial statements and related disclosures .
Sincerely,
/s/Tia L. Jenkins
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Mail Stop 3561 December 2 2, 2015 Via E -mail Mr. Brian L. Cantrell Chief Financial Officer Alliance Resource Partners, L.P. 1717 South Boulder Avenue Suite 400 Tulsa, O K 74119 Re: Alliance Resource Partners, L.P. Form 10-K for the Year Ended December 31, 2014 Filed February 27, 2015 Response Dated December 3, 2015 File 0 -26823 Dear Mr. Cantrell : We have reviewed your December 3, 2015 response to our comment letter 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 busine ss days by providing the requested information or advis e 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. Unless we no te otherwise, our references to our prior comments are to comments in our November 3, 2015 letter. Form 10 -K for the Year Ended December 31, 2014 Consolidated Financial Statements Note 1. Organization and Presentation Organization, page 79 1. Your response to comment 2 and your proposed disclosures with respect to both the Intermediate Partnership and Alliance Coal, LLC indicate that you are consolidating each of these entities because you or the Intermediate Partnership are the primary benefic iaries of these entities. Given this factor and the significance of these entities to your consolidated financial statements, please revise future filings to include all of the Mr. Brian L. Cantrell Alliance Resource Partners, L.P. December 2 2, 2015 Page 2 disclosures outlined in ASC 810 -10-50-2AA, 810 -10-50-3, and ASC 810 -50-5A, as applicable. Please provide us your proposed disclosures. If you believe certain disclosures outlined in the ASC guidance noted above are not applicable, please also explain to us the basis for those conclusions. You may contact Linda Cvrkel at (202) 551-3813 or Rufus Decker, Accounting Branch Chief , at (202) 551-3769 with any questions regarding comments on your financial statements and related disclosures . Sincerely, /s/Tia L. Jenkins Tia L. Jenkins Senior Assistant Chief Accountant Office of Beverages, Appare l and Mining