SEC Comment Letter 0000000000-24-010141 to NATURAL RESOURCE PARTNERS LP (NRP) (CIK 0001171486) (NRP)
NATURAL RESOURCE PARTNERS LP (NRP) (CIK 0001171486)
Date: Sept. 6, 2024 · CIK: 0001171486 · Accession: 0000000000-24-010141
AI Filing Summary & Sentiment
File numbers found in text: 001-31465
Letter
September 6, 2024 Chris Zolas Chief Financial Officer Natural Resource Partners LP 1415 Louisiana Street, Suite 3325 Houston, Texas 77002 Re:Natural Resource Partners LP Form 10-K for the Fiscal Year ended December 31, 2023 Filed March 7, 2024 File No. 001-31465 Dear Chris Zolas: We have reviewed your July 29, 2024 response to our comment letter and have the following comment. Please respond to this letter within ten business days by providing the requested information or advise us as soon as possible when you will respond. If you do not believe a comment applies to your facts and circumstances, please tell us why in your response. After reviewing your response to this letter, we may have additional comments. Unless we note otherwise, any references to prior comments are to comments in our May 24, 2024 letter. Form 10-K for the Fiscal Year ended December 31, 2023 Business and Properties, page 10 We note your response to prior comment two indicates, in part, that you do not have a contractual right to require that Sisecam provide to a qualified person the information necessary to produce a technical report summary pursuant to Subpart 1300 of Regulation S-K, and therefore, you regard this information as not "reasonably available." You further indicate, based on this assessment, that you do not believe you are required to fully comply with Subpart 1300 of Regulation S-K, in reliance on Rule 12b-21.
However, you also state that Sisecam has agreed to assist in providing “information that is not otherwise available” to you to the qualified person and to cooperate with the qualified person in the preparation of a new technical report summary. Given Sisecam’s willingness to assist in providing information and to cooperate with the qualified person, we are not in position to agree with your conclusion that necessary information is not “reasonably 1.
September 6, 2024 Page 2 available” to you. Accordingly, you will need to revise your disclosure to fully comply with Subpart 1300 of Regulation S-K, to include filing a technical report summary with all of the content prescribed by Item 601(b)(96) of Regulation S-K.
Please contact John Coleman at 202-551-3610 or Karl Hiller at 202-551-3686 if you have questions regarding the comment. Sincerely, Division of Corporation Finance Office of Energy & Transportation
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September 6, 2024
Chris Zolas
Chief Financial Officer
Natural Resource Partners LP
1415 Louisiana Street, Suite 3325
Houston, Texas 77002
Re:Natural Resource Partners LP
Form 10-K for the Fiscal Year ended December 31, 2023
Filed March 7, 2024
File No. 001-31465
Dear Chris Zolas:
We have reviewed your July 29, 2024 response to our comment letter and have the
following comment.
Please respond to this letter within ten business days by providing the requested
information or advise us as soon as possible when you will respond. If you do not believe a
comment applies to your facts and circumstances, please tell us why in your response.
After reviewing your response to this letter, we may have additional comments. Unless we
note otherwise, any references to prior comments are to comments in our May 24, 2024 letter.
Form 10-K for the Fiscal Year ended December 31, 2023
Business and Properties, page 10
We note your response to prior comment two indicates, in part, that you do not have a
contractual right to require that Sisecam provide to a qualified person the information
necessary to produce a technical report summary pursuant to Subpart 1300 of Regulation
S-K, and therefore, you regard this information as not "reasonably available." You further
indicate, based on this assessment, that you do not believe you are required to fully
comply with Subpart 1300 of Regulation S-K, in reliance on Rule 12b-21.
However, you also state that Sisecam has agreed to assist in providing “information that is
not otherwise available” to you to the qualified person and to cooperate with the qualified
person in the preparation of a new technical report summary. Given Sisecam’s willingness
to assist in providing information and to cooperate with the qualified person, we are not in
position to agree with your conclusion that necessary information is not “reasonably 1.
September 6, 2024
Page 2
available” to you. Accordingly, you will need to revise your disclosure to fully comply
with Subpart 1300 of Regulation S-K, to include filing a technical report summary with
all of the content prescribed by Item 601(b)(96) of Regulation S-K.
Please contact John Coleman at 202-551-3610 or Karl Hiller at 202-551-3686 if you have
questions regarding the comment.
Sincerely,
Division of Corporation Finance
Office of Energy & Transportation