SEC Comment Letter for NATURAL RESOURCE PARTNERS LP (NRP) (CIK 0001171486) (NRP) — Oct 17, 2013
NATURAL RESOURCE PARTNERS LP (NRP) (CIK 0001171486)
Date: Oct. 17, 2013 · CIK: 0001171486 · Accession: 0000000000-13-057241
AI Filing Summary & Sentiment
Letter
October 1 7, 2013 Via E -mail Mr. Dwight L. Dunlap Chief Financial Officer Natural Resource Partners L.P. 601 Jefferson Street Suite 3600 Houston, TX 77002
Re: Natural Resource Partners L.P. Form 10 -K for the Year Ended December 31, 2012 Filed February 28, 2013 Form 10 -Q for the Quarter Ended June 30, 2013 Filed August 7, 2013 File No. 001 -31465
Dear Mr. Dunlap :
We have reviewed your filing s and have the following comment. We have limited our review to only your financial statements and related disclosures and do not intend to expand our review to other portions of your documents. In some of our comments, we may ask you to provide us with inf ormation so we may better understand your disclosure.
Please respond to this letter within ten business days by providing the requested information or by advising us when you will provide the requested response. If you do not believe our comment applies to your facts and circumstances, please tell us why in your response.
After reviewing the information you provide in response to th is comment, w e may have additional comments.
Form 10-Q for the Quarter Ended June 30, 2013
Consolidated Statements of Comprehensive Income, page 5
1. We note you present “equity and other unconsolidated investment income, net” as a component of total revenue. Please tell us why you consider this item to be a component of revenue.
Mr. Dwight L. Dunlap Natural Res ource Partners L.P. October 1 7, 2013 Page 2
We urge all persons who are responsible for the accuracy and adequacy of the disclosure in the filing to be certain that the filing includes the information the Securities Exchange Act of 1934 and all applicable Exchange Act rules require. Since the company and its management are in possession o f all facts relating to a company’s disclosure, they are responsible for the accuracy and adequacy of the disclosures they have made.
In responding to our comments, please provide a written statement from the company acknowledging that:
the company is responsible for the adequacy and accuracy of the disclosure in the filing;
staff comments or changes to disclosure in response to staff comments do not foreclose the Commission from taking any action with respect to the filing; and
the company may not as sert staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.
You may contact James Giugliano at (202) 551 -3319, or Rufus Decker at (202) 551 - 3769, if you have questio ns regarding comments on the financial statements and related matters. Please contact me at (202) 551 -3871 with any other questions.
Sincerely,
/s/Tia L. Jenkins
Show Raw Text
October 1 7, 2013
Via E -mail
Mr. Dwight L. Dunlap
Chief Financial Officer
Natural Resource Partners L.P.
601 Jefferson Street
Suite 3600
Houston, TX 77002
Re: Natural Resource Partners L.P.
Form 10 -K for the Year Ended December 31, 2012
Filed February 28, 2013
Form 10 -Q for the Quarter Ended June 30, 2013
Filed August 7, 2013
File No. 001 -31465
Dear Mr. Dunlap :
We have reviewed your filing s and have the following comment. We have limited our
review to only your financial statements and related disclosures and do not intend to expand our
review to other portions of your documents. In some of our comments, we may ask you to
provide us with inf ormation so we may better understand your disclosure.
Please respond to this letter within ten business days by providing the requested
information or by advising us when you will provide the requested response. If you do not
believe our comment applies to your facts and circumstances, please tell us why in your
response.
After reviewing the information you provide in response to th is comment, w e may have
additional comments.
Form 10-Q for the Quarter Ended June 30, 2013
Consolidated Statements of Comprehensive Income, page 5
1. We note you present “equity and other unconsolidated investment income, net” as a
component of total revenue. Please tell us why you consider this item to be a component
of revenue.
Mr. Dwight L. Dunlap
Natural Res ource Partners L.P.
October 1 7, 2013
Page 2
We urge all persons who are responsible for the accuracy and adequacy of the disclosure
in the filing to be certain that the filing includes the information the Securities Exchange Act of
1934 and all applicable Exchange Act rules require. Since the company and its management are
in possession o f all facts relating to a company’s disclosure, they are responsible for the accuracy
and adequacy of the disclosures they have made.
In responding to our comments, please provide a written statement from the company
acknowledging that:
the company is responsible for the adequacy and accuracy of the disclosure in the filing;
staff comments or changes to disclosure in response to staff comments do not foreclose
the Commission from taking any action with respect to the filing; and
the company may not as sert staff comments as a defense in any proceeding initiated by
the Commission or any person under the federal securities laws of the United States.
You may contact James Giugliano at (202) 551 -3319, or Rufus Decker at (202) 551 -
3769, if you have questio ns regarding comments on the financial statements and related matters.
Please contact me at (202) 551 -3871 with any other questions.
Sincerely,
/s/Tia L. Jenkins
Tia L. Jenkins
Senior Assistant Chief Accountant
Office of Beverages, Apparel, and
Mining