SEC Comment Letter for BATTALION OIL CORP (BATL) (CIK 0001282648) (BATL) — Feb 7, 2014
BATTALION OIL CORP (BATL) (CIK 0001282648)
Date: Feb. 7, 2014 · CIK: 0001282648 · Accession: 0000000000-14-006666
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 001-35467
Referenced dates: December 30, 2013, January 20, 2014
Letter
February 7, 2014 Via E -mail Mark J. Mize Executive Vice President, Chief Financial Officer and Treasurer Halcon Resources Corporation 1000 Louisiana Street, Suite 6700 Houston, TX 77002
Re: Halcon Resources Corporation Form 10 -K for the Fiscal Year e nded December 31, 2012 Filed February 28, 2013 Form 10 -Q for the Quarterly Period ended September 30, 2013 Filed November 4, 2013 Response letter dated January 20, 2014 File No . 001-35467
Dear Mr. Mize :
We have reviewed your filings and response letter and have the following additional comments.
Please respond to this letter within ten business days by amending your filing s, by providing the requested information, or by advisi ng us when you will provide the requested response. If you do not believe our comments apply to your facts and cir cumstances or do not believe amendment s are appropriate, please tell us why in your response.
After reviewing any amendment s to your filin gs and the information you provide in response to these comments , we may have additional comments.
Form 10-K for the Fiscal Year ended December 31, 2012
Business, page 7
Oil and Natural Gas Operations, page 18
1. We note from your response to comment one in our letter dated December 30, 2013 that after giving effect to property dispositions made in 2013, 6.2 MMboe of proved undeveloped reserves were assigned to locations scheduled to be drilled after lease expirati on. We also note the proved reserves assigned to these locations appear to be material to your total proved reserves and significant in relation to your total proved undeveloped reserves. Please refer to FASB ASC 932 -235-50-10 and provide disclosure
Mark J. Mize Halcon Resources Corporation February 07 , 2014 Page 2
of the steps you will take to maintain the legal right to those leases with proved undeveloped locations that are not scheduled to be drilled until after lease expiration.
Form 10 -Q for the Quarterly Period ended September 30, 2013
Management’s Discussion an d Analysis of Financial Condition and Results of Operations, page
Capital Resources and Liquidity, page 43
2. We note from your response to prior comment number 7 that you have sought and successfully obtained waivers or amendments to your financial covenants when you anticipated that you might have temporary difficulty maintaining compliance with, or might be unduly limited by one or more covenants. We note from your disclosure that you have highlighted these waivers and amendments, although not necessarily fully discussing the underlying facts leading up to the waivers and amendments. Please revise your disclosure to more fully discuss these underlying facts when necessary to an understanding of your financial condition or change in financial condition. Refer to Item 303(a) of Regulation S -K.
You may contact Michael Fay, Staff Accountant, at (202) 551 -3812 or Mark Wojciechowski, Staff Accountant, at (202) 551 -3759 if you have questions regarding comments on the financial s tatements and related matters and John Hodgin, P etroleum Engineer, at (202) 551-3699 if you have questions regarding the comments on engineering matters . Please contact me at (202) 551 -3745 with any other questions.
Sincerely,
/s/ Brad Skinner for
Show Raw Text
February 7, 2014
Via E -mail
Mark J. Mize
Executive Vice President, Chief Financial Officer and Treasurer
Halcon Resources Corporation
1000 Louisiana Street, Suite 6700
Houston, TX 77002
Re: Halcon Resources Corporation
Form 10 -K for the Fiscal Year e nded December 31, 2012
Filed February 28, 2013
Form 10 -Q for the Quarterly Period ended September 30, 2013
Filed November 4, 2013
Response letter dated January 20, 2014
File No . 001-35467
Dear Mr. Mize :
We have reviewed your filings and response letter and have the following additional
comments.
Please respond to this letter within ten business days by amending your filing s, by
providing the requested information, or by advisi ng us when you will provide the requested
response. If you do not believe our comments apply to your facts and cir cumstances or do not
believe amendment s are appropriate, please tell us why in your response.
After reviewing any amendment s to your filin gs and the information you provide in
response to these comments , we may have additional comments.
Form 10-K for the Fiscal Year ended December 31, 2012
Business, page 7
Oil and Natural Gas Operations, page 18
1. We note from your response to comment one in our letter dated December 30, 2013 that
after giving effect to property dispositions made in 2013, 6.2 MMboe of proved
undeveloped reserves were assigned to locations scheduled to be drilled after lease
expirati on. We also note the proved reserves assigned to these locations appear to be
material to your total proved reserves and significant in relation to your total proved
undeveloped reserves. Please refer to FASB ASC 932 -235-50-10 and provide disclosure
Mark J. Mize
Halcon Resources Corporation
February 07 , 2014
Page 2
of the steps you will take to maintain the legal right to those leases with proved
undeveloped locations that are not scheduled to be drilled until after lease expiration.
Form 10 -Q for the Quarterly Period ended September 30, 2013
Management’s Discussion an d Analysis of Financial Condition and Results of Operations, page
41
Capital Resources and Liquidity, page 43
2. We note from your response to prior comment number 7 that you have sought and
successfully obtained waivers or amendments to your financial covenants when you
anticipated that you might have temporary difficulty maintaining compliance with, or
might be unduly limited by one or more covenants. We note from your disclosure that
you have highlighted these waivers and amendments, although not necessarily fully
discussing the underlying facts leading up to the waivers and amendments. Please revise
your disclosure to more fully discuss these underlying facts when necessary to an
understanding of your financial condition or change in financial condition. Refer to Item
303(a) of Regulation S -K.
You may contact Michael Fay, Staff Accountant, at (202) 551 -3812 or Mark
Wojciechowski, Staff Accountant, at (202) 551 -3759 if you have questions regarding comments
on the financial s tatements and related matters and John Hodgin, P etroleum Engineer, at (202)
551-3699 if you have questions regarding the comments on engineering matters . Please contact
me at (202) 551 -3745 with any other questions.
Sincerely,
/s/ Brad Skinner for
H. Roger Schwall
Assistant Director