SEC Comment Letter for SILVERCORP METALS (SVM) — Jun 25, 2013
SILVERCORP METALS INC
Date: June 25, 2013 · CIK: 0001340677 · Accession: 0000000000-13-034584
AI Filing Summary & Sentiment
Letter
June 25 , 2013 Via E -Mail Dr. Rui Feng Chief Executive Officer Silvercorp Metals, Inc. Suite 1378 -200 Granville Street Vancouver, BC Canada V6C 15 4
Re: Silvercorp Metals, Inc. Form 40-F for Fiscal Year Ended March 31, 2012 Filed June 29, 2012 Response dated June 4 , 2013 File No. 001 -34184
Dear Dr. Feng :
We have reviewed your filing an d have the following comment .
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 d o not believe our comment applies to your facts and circumstanc es 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 this commen t, we may have additional comments.
Form 6 -K file d May 23, 2012
Exhibit 99.2
Management’s Discussion and Analysis
4. Fiscal Year 2012 Operating Performance
(vi) Cash and Total Cost per Ounce of Silver (Gold for the BYP mine), page 4 1. We have considered your response to our prior comment 3. We continu e to believe the presentation of these non -IFRS measures, total production cost per ounce of silver and gold, and cash cost per ounce of s ilver and gold which deduct material by -product sales related to lead, zinc and gold, are inappropriate because they p lace too much emphasis on a measure that materially distorts your actual production costs. Please revise accordingly and amend your Form 40 -F as appropriate to comply.
Dr. Rui Feng Silvercorp Metals Inc. June 25 , 2013 Page 2
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 Securities 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 have made.
You may contact Jamie Kessel, Staff Accountant, at 202 -551-3727 or Raj Rajan, Senior Staff Accountant, at 202 -551-3388 if you have questions regarding comments on the financial statements and related matters.
Sincerely,
/s/Tia L. Jenkins
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June 25 , 2013 Via E -Mail Dr. Rui Feng Chief Executive Officer Silvercorp Metals, Inc. Suite 1378 -200 Granville Street Vancouver, BC Canada V6C 15 4 Re: Silvercorp Metals, Inc. Form 40-F for Fiscal Year Ended March 31, 2012 Filed June 29, 2012 Response dated June 4 , 2013 File No. 001 -34184 Dear Dr. Feng : We have reviewed your filing an d have the following comment . 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 d o not believe our comment applies to your facts and circumstanc es 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 this commen t, we may have additional comments. Form 6 -K file d May 23, 2012 Exhibit 99.2 Management’s Discussion and Analysis 4. Fiscal Year 2012 Operating Performance (vi) Cash and Total Cost per Ounce of Silver (Gold for the BYP mine), page 4 1. We have considered your response to our prior comment 3. We continu e to believe the presentation of these non -IFRS measures, total production cost per ounce of silver and gold, and cash cost per ounce of s ilver and gold which deduct material by -product sales related to lead, zinc and gold, are inappropriate because they p lace too much emphasis on a measure that materially distorts your actual production costs. Please revise accordingly and amend your Form 40 -F as appropriate to comply. Dr. Rui Feng Silvercorp Metals Inc. June 25 , 2013 Page 2 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 Securities 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 have made. You may contact Jamie Kessel, Staff Accountant, at 202 -551-3727 or Raj Rajan, Senior Staff Accountant, at 202 -551-3388 if you have questions regarding comments on the financial statements and related matters. Sincerely, /s/Tia L. Jenkins Tia L. Jenkins Senior Assistant Chief Accountant Office of Beverages, Apparel , and Mining