SEC Comment Letter for CEMENTOS PACASMAYO SAA (CPAC) (CIK 0001221029) (CPAC) — Feb 10, 2014
CEMENTOS PACASMAYO SAA (CPAC) (CIK 0001221029)
Date: Feb. 10, 2014 · CIK: 0001221029 · Accession: 0000000000-14-006904
AI Filing Summary & Sentiment
Reasoning
Referenced dates: January 15, 2014
Letter
February 10, 2014 Via Email Mr. Manuel Ferreyros Peña Chief Financial Officer Cementos Pacasmayo S.A.A. Calle La Colonia 150 Urb. El Vivero -Lima, Peru
Re: Cementos Pacasmayo S.A.A. Form 20-F for Fiscal Year Ended December 31, 2012 Filed April 30, 2013 Response Letter Dated January 15, 2014 File No. 1-35401
Dear Mr. Peña :
We have reviewed your filing and have the following comments. 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 amending your filing, by providing the requested information, or by advising us when you will provide the requested response . If you do not believe our comments apply to your facts and circumstances or do not believe an amendment is appropriate, please tell us why in your response.
After reviewing any amendment to your filing and the information you provide in response to these comments, we may have additional comments.
Form 20 -F for Fiscal Year Ended December 31, 2012
Operating and Financial Review and Prospects, page 51
Critical Accounting Policies, page 54
Exploration, Evaluation and Mine Development Projects, page 55
1. We have read your response to prior comment 3, in our letter to you dated December 19, 2013, in which you indicate that you will revise your disclosure regarding the capitalization of exploration and evaluation assets to provide additional informat ion regarding the estimates and assumptions necessary to determine whether an economically viable extraction operation can be established such that it is more likely than not that these costs will be realized. Please provide the proposed disclosure revisio ns that you
Mr. Manuel Ferreyros Peña Cementos Pacasmayo S.A.A. February 10, 2014 Page 2
would have included in your filing that identify the significant estimates, assumptions, and judgments you use to make this determination.
Financial Statements, page 105
Note 29 - Fair value of financial instruments, page F -63
2. We have read your response to prior comment 11 in which you indicate that in future filings you will expand the considerations for the determination of the value of the put and call option on your results of operations. Please provide the proposed disclosure revisions that you would have included in your filing which explain how you determined the fair value of the put and call option.
Closing Comments
You may contact Tracie Towner at (202) 551 -3744 , or Jeanne Baker at (202) 551 - 3691, if you have questions regarding comments on the financial statements and related matters. Please contact me at (202) 551 -3355 with any other questions.
Sincerely,
/s/ Terence O ’Brien
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February 10, 2014 Via Email Mr. Manuel Ferreyros Peña Chief Financial Officer Cementos Pacasmayo S.A.A. Calle La Colonia 150 Urb. El Vivero -Lima, Peru Re: Cementos Pacasmayo S.A.A. Form 20-F for Fiscal Year Ended December 31, 2012 Filed April 30, 2013 Response Letter Dated January 15, 2014 File No. 1-35401 Dear Mr. Peña : We have reviewed your filing and have the following comments. 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 amending your filing, by providing the requested information, or by advising us when you will provide the requested response . If you do not believe our comments apply to your facts and circumstances or do not believe an amendment is appropriate, please tell us why in your response. After reviewing any amendment to your filing and the information you provide in response to these comments, we may have additional comments. Form 20 -F for Fiscal Year Ended December 31, 2012 Operating and Financial Review and Prospects, page 51 Critical Accounting Policies, page 54 Exploration, Evaluation and Mine Development Projects, page 55 1. We have read your response to prior comment 3, in our letter to you dated December 19, 2013, in which you indicate that you will revise your disclosure regarding the capitalization of exploration and evaluation assets to provide additional informat ion regarding the estimates and assumptions necessary to determine whether an economically viable extraction operation can be established such that it is more likely than not that these costs will be realized. Please provide the proposed disclosure revisio ns that you Mr. Manuel Ferreyros Peña Cementos Pacasmayo S.A.A. February 10, 2014 Page 2 would have included in your filing that identify the significant estimates, assumptions, and judgments you use to make this determination. Financial Statements, page 105 Note 29 - Fair value of financial instruments, page F -63 2. We have read your response to prior comment 11 in which you indicate that in future filings you will expand the considerations for the determination of the value of the put and call option on your results of operations. Please provide the proposed disclosure revisions that you would have included in your filing which explain how you determined the fair value of the put and call option. Closing Comments You may contact Tracie Towner at (202) 551 -3744 , or Jeanne Baker at (202) 551 - 3691, if you have questions regarding comments on the financial statements and related matters. Please contact me at (202) 551 -3355 with any other questions. Sincerely, /s/ Terence O ’Brien Terence O’Brien Branch Chief