SEC Comment Letter for MAG SILVER CORP (MAG) (CIK 0001230992) — Dec 9, 2005
MAG SILVER CORP (MAG) (CIK 0001230992)
Date: Dec. 9, 2005 · CIK: 0001230992 · Accession: 0000000000-05-061635
AI Filing Summary & Sentiment
Letter
December 9, 2005 Mr. Frank R. Hallam, Chief Financial Officer MAG Silver Corp. Suite 328, 550 Burrard Street Vancouver, British Columbia CANADA V6C 2B5
Re: MAG Silver Corp. Form 20-F for Fiscal Year Ended December 31, 2004 Filed June 29, 2005 File No. 0-50437
Dear Mr. Hallam:
We have reviewed your filing and have the following comments. We have limited our review of your filing to those issues we have addressed in our comments. Where indicated, we think you should revise your document in response to these comments. If you disagree, we will consider your explanation as to why our comment is inapplicable or a revision is unnecessary. Please be as detailed as necessary in your explanation. In some of our comments, we may ask you to provide us with information so we may better understand your disclosure. After reviewing this information, we may raise additional comments.
Please understand that the purpose of our review process is to assist you in your compliance with the applicable disclosure requirements and to enhance the overall disclosure in your filing. We look forward to working with you in these respects. We welcome any questions you may have about our comments or any other aspect of our review. Feel free to call us at the telephone numbers listed at the end of this letter.
Form 20-F for the Fiscal Year Ended December 31, 2004
Item 11 - Quantitative and Qualitative Disclosure about Market Risk, page 56
1. Your disclosures on page 49 indicate that 20% of your operations are in Canadian dollars, while other disclosures indicate your properties and operations are in Mexico. Tell us how you determined that the disclosures under Item 11 with regard to foreign currency exchange risk were not applicable, or provide such disclosures.
Item 17 - Financial Statements
2. The Independent Auditors` Report is not manually signed by the auditing firm as required by Regulation S-X 2-02. Please provide a signed report.
Closing Comments
As appropriate, please amend your filing and respond to these comments within 10 business days or tell us when you will provide us with a response. You may wish to provide us with marked copies of the amendment to expedite our review. Please furnish a cover letter with your amendment that keys your responses to our comments and provides any requested information. Detailed cover letters greatly facilitate our review. Please understand that we may have additional comments after reviewing your amendment and responses to our comments.
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 all information required under the Securities Exchange Act of 1934 and that they have provided all information investors require for an informed investment decision. 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 have made.
In connection with responding to our comments, please provide, in writing, a 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 response 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 laws of the United States.
In addition, please be advised that the Division of Enforcement has access to all information you provide to the staff of the Division of Corporation Finance in our review of your filing or in response to our comments on your filing.
You may contact Gary Newberry at (202) 551-3761 if you have questions regarding comments on the financial statements and related matters. Please contact me at (202) 551- 3684 with any other questions.
Sincerely,
April Sifford
Branch Chief
Show Raw Text
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December 9, 2005
Mr. Frank R. Hallam, Chief Financial Officer
MAG Silver Corp.
Suite 328, 550 Burrard Street
Vancouver, British Columbia
CANADA V6C 2B5
Re: MAG Silver Corp.
Form 20-F for Fiscal Year Ended December 31, 2004
Filed June 29, 2005
File No. 0-50437
Dear Mr. Hallam:
We have reviewed your filing and have the following
comments.
We have limited our review of your filing to those issues we have
addressed in our comments. Where indicated, we think you should
revise your document in response to these comments. If you
disagree,
we will consider your explanation as to why our comment is
inapplicable or a revision is unnecessary. Please be as detailed
as
necessary in your explanation. In some of our comments, we may
ask
you to provide us with information so we may better understand
your
disclosure. After reviewing this information, we may raise
additional comments.
Please understand that the purpose of our review process is
to
assist you in your compliance with the applicable disclosure
requirements and to enhance the overall disclosure in your filing.
We look forward to working with you in these respects. We welcome
any questions you may have about our comments or any other aspect
of
our review. Feel free to call us at the telephone numbers listed
at
the end of this letter.
Form 20-F for the Fiscal Year Ended December 31, 2004
Item 11 - Quantitative and Qualitative Disclosure about Market
Risk,
page 56
1. Your disclosures on page 49 indicate that 20% of your
operations
are in Canadian dollars, while other disclosures indicate your
properties and operations are in Mexico. Tell us how you
determined
that the disclosures under Item 11 with regard to foreign currency
exchange risk were not applicable, or provide such disclosures.
Item 17 - Financial Statements
2. The Independent Auditors` Report is not manually signed by the
auditing firm as required by Regulation S-X 2-02. Please provide
a
signed report.
Closing Comments
As appropriate, please amend your filing and respond to
these
comments within 10 business days or tell us when you will provide
us
with a response. You may wish to provide us with marked copies of
the amendment to expedite our review. Please furnish a cover
letter
with your amendment that keys your responses to our comments and
provides any requested information. Detailed cover letters
greatly
facilitate our review. Please understand that we may have
additional
comments after reviewing your amendment and responses to our
comments.
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 all information required under the Securities
Exchange Act of 1934 and that they have provided all information
investors require for an informed investment decision. 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 have made.
In connection with responding to our comments, please
provide,
in writing, a 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 response 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 laws of the United States.
In addition, please be advised that the Division of
Enforcement
has access to all information you provide to the staff of the
Division of Corporation Finance in our review of your filing or in
response to our comments on your filing.
You may contact Gary Newberry at (202) 551-3761 if you have
questions regarding comments on the financial statements and
related
matters. Please contact me at (202) 551- 3684 with any other
questions.
Sincerely,
April Sifford
Branch Chief
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Mr. Frank R. Hallam
MAG Silver Corp.
December 9, 2005
page 1
UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
100 F Street, N.E.
WASHINGTON, D.C. 20549-7010
DIVISION OF
CORPORATION FINANCE
MAIL STOP 7010
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