SEC Comment Letter for NATURAL RESOURCE PARTNERS LP (NRP) (CIK 0001171486) (NRP) — Oct 25, 2013
NATURAL RESOURCE PARTNERS LP (NRP) (CIK 0001171486)
Date: Oct. 25, 2013 · CIK: 0001171486 · Accession: 0000000000-13-058849
AI Filing Summary & Sentiment
Letter
October 24, 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 Fiscal Year Ended December 31, 2012 Filed February 28, 2013 Form 10 -Q for Fiscal Quarter Ended June 30, 2013 Filed August 7, 2013 Response dated October 22, 2013 File No. 001 -31465
Dear Mr. Dunlap :
We have reviewed your response 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 information so we may better understand your disclosur e.
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 inform ation you provide in response to this comment, we may have additional comments.
Form 10 -Q for Fiscal Quarter Ended June 30, 2013
Consolidated Statements of Comprehensive Income, page 5
1. We note your response to our prior comment 1 appears to address your basis for classification of “equity and other unconsolidated investment income, net” as operating versus non -operating. Please note that our comment was focused on why “equity and other unconsol idated investment income, net” is a component of revenue versus an
Mr. Dwight L. Dunlap Natural Res ource Partners L.P. October 24, 2013 Page 2
operating gain excluded from total revenue. Please tell us why you consider this item to be a component of revenue .
You may contact James Giugliano at (202) 551 -3319, or Rufus Decker a t (202) 551 -3769, if you have questions regarding comments on the financial statements and related matters. Please contact me at (202) 551 -3871 with any other questions.
Sincerely,
/s/ Rufus Decker for
Show Raw Text
October 24, 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 Fiscal Year Ended December 31, 2012
Filed February 28, 2013
Form 10 -Q for Fiscal Quarter Ended June 30, 2013
Filed August 7, 2013
Response dated October 22, 2013
File No. 001 -31465
Dear Mr. Dunlap :
We have reviewed your response 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 information so we may better understand your disclosur e.
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 inform ation you provide in response to this comment, we may have
additional comments.
Form 10 -Q for Fiscal Quarter Ended June 30, 2013
Consolidated Statements of Comprehensive Income, page 5
1. We note your response to our prior comment 1 appears to address your basis for
classification of “equity and other unconsolidated investment income, net” as operating
versus non -operating. Please note that our comment was focused on why “equity and
other unconsol idated investment income, net” is a component of revenue versus an
Mr. Dwight L. Dunlap
Natural Res ource Partners L.P.
October 24, 2013
Page 2
operating gain excluded from total revenue. Please tell us why you consider this item to
be a component of revenue .
You may contact James Giugliano at (202) 551 -3319, or Rufus Decker a t (202) 551 -3769,
if you have questions regarding comments on the financial statements and related matters. Please
contact me at (202) 551 -3871 with any other questions.
Sincerely,
/s/ Rufus Decker for
Tia L. Jenkins
Senior Assistant Chief Accountant
Office of Beverages, Apparel, and
Mining