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
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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