SEC Comment Letter for CEMENTOS PACASMAYO SAA (CPAC) — Jan 23, 2018
CEMENTOS PACASMAYO SAA
Date: Jan. 23, 2018 · CIK: 0001221029 · Accession: 0000000000-18-002348
AI Filing Summary & Sentiment
Referenced dates: December 19, 2017
Letter
January 22, 2018 Mail Stop 4631 Via E -mail Mr. Manuel Bartolome 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, 2016 Filed April 28, 2017 Response dated January 4, 2018 File No. 1-35401
Dear Mr. Pena :
We have reviewed your response and have the following additional comment s. 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 do not believe our comments apply to your facts and circumstances, please tell us why in your response.
After reviewing the information you provide in response to these comments, we may have additional comments.
Form 20 -F for the period ended December 31, 2016
Note 1 Corporate Information, page F -9
1. We note your response to our comment number 2 from our letter dated December 19, 2017. Please further clarify how you considered paragraphs BC13 and BC 14 of IFR IC 17 in determining that the spin -off transaction was not within the scope of IFRIC 17. Tell us how you considered the common share ownership of ASPI in your analysis.
Mr. Pena Cementos Pacasmayo S.A.A. January 22, 2018 Page 2
You may contact Ameen Hamady , Staff Accountant, at (202) 551 -3891, or in his absence, me at (202) 551 -3355 , if you have questions regarding comments on the financial statements and related matters. Please contac t Frank Pigott at (202) 551 -3570 , or in his absence, Pamela Long, Assis tant Director, at (202) 551 -3765 with any other qu estions.
Sincerely,
/s/ Terence O ’Brien
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January 22, 2018 Mail Stop 4631 Via E -mail Mr. Manuel Bartolome 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, 2016 Filed April 28, 2017 Response dated January 4, 2018 File No. 1-35401 Dear Mr. Pena : We have reviewed your response and have the following additional comment s. 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 do not believe our comments apply to your facts and circumstances, please tell us why in your response. After reviewing the information you provide in response to these comments, we may have additional comments. Form 20 -F for the period ended December 31, 2016 Note 1 Corporate Information, page F -9 1. We note your response to our comment number 2 from our letter dated December 19, 2017. Please further clarify how you considered paragraphs BC13 and BC 14 of IFR IC 17 in determining that the spin -off transaction was not within the scope of IFRIC 17. Tell us how you considered the common share ownership of ASPI in your analysis. Mr. Pena Cementos Pacasmayo S.A.A. January 22, 2018 Page 2 You may contact Ameen Hamady , Staff Accountant, at (202) 551 -3891, or in his absence, me at (202) 551 -3355 , if you have questions regarding comments on the financial statements and related matters. Please contac t Frank Pigott at (202) 551 -3570 , or in his absence, Pamela Long, Assis tant Director, at (202) 551 -3765 with any other qu estions. Sincerely, /s/ Terence O ’Brien Terence O’ Brien Accounting Branch Chief Office of Manufacturing and Construction