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SEC Comment Letter for NATURAL RESOURCE PARTNERS LP (NRP) (CIK 0001171486) (NRP) — Nov 1, 2013

NATURAL RESOURCE PARTNERS LP (NRP) (CIK 0001171486)
Date: Nov. 1, 2013 · CIK: 0001171486 · Accession: 0000000000-13-060294

AI Filing Summary & Sentiment

Date
November 1, 2013
Author
/s/Tia L. Jenkins
Form
UPLOAD
Company
NATURAL RESOURCE PARTNERS LP (NRP) (CIK 0001171486)

Letter

November 1, 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 Response dated October 2 9, 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 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 d o 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 the Quarter Ended June 30, 2013

Consolidated Statements of Comprehensive Income, page 5

1. We note your response to our prior comment. In order to highlight that the “Revenues” section includes equity in the earnings of unconsolidated investments, please modify your titles “Revenues” and “Total Revenues” in future filings to better reflect the amounts included (e.g. “Revenues and Other Income”).

Mr. Dwight L. Dunlap Natural Res ource Partners L.P. November 1 , 2013 Page 2

You may contact James Giugliano at (202) 551 -3319, or Rufus Decker at (202) 551 - 3769, if you have questions re garding 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
November 1, 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
  Response dated  October 2 9, 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 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 d o 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 the Quarter Ended June 30, 2013

Consolidated Statements of Comprehensive Income, page 5

1. We note your response to our prior comment.  In order  to highlight that the “Revenues”
section includes equity in the earnings of unconsolidated investments, please modify your
titles “Revenues” and “Total Revenues” in future filings to better reflect the amounts
included (e.g. “Revenues and Other Income”).

Mr. Dwight L.  Dunlap
Natural Res ource Partners L.P.
November 1 , 2013
Page 2

  You may contact James Giugliano at (202) 551 -3319, or Rufus Decker at (202) 551 -
3769, if you have questions re garding 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