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SEC Comment Letter for CEMENTOS PACASMAYO SAA (CPAC) (CIK 0001221029) (CPAC) — Dec 4, 2015

CEMENTOS PACASMAYO SAA (CPAC) (CIK 0001221029)
Date: Dec. 4, 2015 · CIK: 0001221029 · Accession: 0000000000-15-056519

Financial Reporting Regulatory Compliance Internal Controls

AI Filing Summary & Sentiment

Sentiment
Urgency
Document Type
Confidence
SEC Posture
Company Posture

Summary

Reasoning

Date
December 31, 2014
Author
/s/ Terence O ’Brien
Form
UPLOAD
Company
CEMENTOS PACASMAYO SAA (CPAC) (CIK 0001221029)

Letter

December 4 , 2015 Mail Stop 4631 Via E -mail Mr. Manuel Ferreyros Pena Chief Financial Officer Cementos Pacasmayo S.A.A. Calle La Colonia 150, Urbanizacion El Vivero Surco, Lima Peru

Re: Cementos Pacasmayo S.A.A. Form 20 -F for Fiscal Year Ended December 31, 2014 Filed April 30 , 2015 File No. 1-35401

Dear Mr. Pena :

We have reviewed your filing and have the following comments. 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 lett er 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 comments apply to your facts and circumstances, please tell us why in your response.

After rev iewing the information you provide in response to these comments, we may have additional comments.

Form 20 -F for th e fiscal year ended December 31, 2014

Attestation Report of the Independent Registered Public Accounting Firm, page 112 Report of the Independent Registered Public Accounting Firm, page F -1

1. Please amend your filing to include updated attestation reports by your independent public accounting firm to also include the manual or printed signature of the independent public accounting firm’s name within the body of the filed reports. See PCAOB auditing standard AS 3101.08.

Mr. Pena Cementos Pacasmayo S.A.A. December 4, 2015 Page 2

Item 16F. Change in Registrant’s Certifying Accountant, page 115

2. We note that your independent registered public accounting firm for the fiscal year ended December 31, 2014 appears to be the successor to your previous certifying independent registered public accounting firm. Given that there appears to be a change in the legal entity of the audit firm, please include the disclosure requirements for Item 16F. Change in Registrant’s Certifying Accountant for the Form 20 -F in your amended filing.

We urge all persons who are responsible for the accuracy and adequacy of the disclosure in the filing to be certain that the filing includes the information the Secur ities Exchange Act of 1934 and all applicable Exchange Act rules require. Since the company and its management are in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy and adequacy of the disclosures they ha ve made.

In responding to our comments, please provide a written statement from the company acknowledging that:

 the company is responsible for the adequacy and accuracy of the disclosure in the filing;

 staff comments or changes to disclosure in respon se to staff comments do not foreclose the Commission from taking any action with respect to the filing; and

 the company may not assert staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities law s of the United States.

You may contact Ameen Hamady , Staff Accountant, at (202) 551 -3891, or in his absence, Al Pavot , at (202) 551 -3738 or me at (202) 551 -3355 , if you have questions regarding comments on the financial statements and related matters.

Sincerely,
/s/ Terence O ’Brien

Show Raw Text
December 4 , 2015
Mail Stop 4631

Via E -mail
Mr. Manuel Ferreyros Pena
Chief Financial Officer
Cementos Pacasmayo S.A.A.
Calle La Colonia 150, Urbanizacion El Vivero
Surco, Lima
Peru

Re: Cementos Pacasmayo S.A.A.
 Form 20 -F for Fiscal Year Ended December 31, 2014
Filed April 30 , 2015
File No. 1-35401

Dear Mr. Pena :

We have reviewed your filing and have the following  comments.  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 lett er 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 comments apply to your facts and circumstances, please tell us why in your response.

After rev iewing the information you provide in response to these comments, we may
have additional comments.

Form 20 -F for th e fiscal year  ended December 31, 2014

Attestation Report of the Independent Registered Public Accounting Firm, page 112
Report  of the Independent Registered Public Accounting Firm, page F -1

1. Please amend your filing to include updated attestation reports by your independent
public accounting firm to also include the manual or printed signature of the
independent public accounting  firm’s name within the body of the filed reports.  See
PCAOB auditing standard AS 3101.08.

Mr. Pena
Cementos Pacasmayo S.A.A.
December 4, 2015
Page 2

 Item 16F. Change in Registrant’s Certifying Accountant, page 115

2. We note that your independent registered public accounting firm for the fiscal year
ended December 31, 2014 appears to be the successor to your previous certifying
independent registered public accounting firm.  Given that there appears to be a change
in the legal entity of the audit firm, please include the disclosure requirements for Item
16F. Change in Registrant’s Certifying Accountant for the Form 20 -F in your amended
filing.

We urge all persons who are responsible for the accuracy and adequacy of the disclosure
in the filing to be certain that the filing includes the information the Secur ities Exchange Act of
1934 and all applicable Exchange Act rules require.   Since the company and its management are
in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy
and adequacy of the disclosures they ha ve made.

In responding to our comments, please provide a written statement from the company
acknowledging that:

 the company is responsible for the adequacy and accuracy of the disclosure in the filing;

 staff comments or changes to disclosure in respon se to staff comments do not foreclose
the Commission from taking any action with respect to the filing; and

 the company may not assert staff comments as a defense in any proceeding initiated by
the Commission or any person under the federal securities law s of the United States.

You may contact Ameen Hamady , Staff Accountant, at (202) 551 -3891, or in his
absence,  Al Pavot , at (202) 551 -3738  or me at (202) 551 -3355 , if you have questions regarding
comments on the financial statements and related matters.

Sincerely,

 /s/ Terence O ’Brien

Terence O’ Brien
Accounting Branch Chief
Office of Manufacturing and
Construction