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SEC Comment Letter for RING ENERGY, (REI) — Dec 29, 2015

RING ENERGY, INC.
Date: Dec. 29, 2015 · CIK: 0001384195 · Accession: 0000000000-15-059771

AI Filing Summary & Sentiment

Date
September 30, 2015
Author
/s/ Brad Skinner
Form
UPLOAD
Company
RING ENERGY, INC.

Letter

Mail Stop 4628 December 29 , 2015 William R. Broaddrick Chief Financial Officer Ring Energy, Inc. 901 West Wall St., 3rd Floor Midland, TX 79702

Re: Ring Energy, Inc Form 10 -Q for Fiscal Quarter Ended September 30, 2015 Filed November 9, 2015 File No. 1-36057

Dear Mr. Broaddrick :

We have reviewed your filing an d have the following comments. In some of our comments, we may ask you to provide us with information so we may better understand your disclosure.

Please respond to these comments within ten busine ss days by providing the requested information or advis e us as soon as possible when you will respond. If you do not believe our comments apply to your facts and circums tances, please tell us why in your response.

After reviewing your response to these comments, we may have additional comments.

Form 10 -Q for Fiscal Quarter Ended September 30, 2015

Financial Statements

Note 1 – Basis of Presentation and Significant Accounting Policies

Oil and Gas Properties, page 9

1. You state here that you evaluate oil and gas properties for impairment at least annually. Please tell us how your accounting policy complies with Regulation S -X, Rule 4 - 10(c)(4), which requi res a ceiling test to be performed each period, i.e. quarterly.

2. Disclosure on page 30 of your Form 10 -K for the year ended December 31, 2014 indicates that oil prices below $69.99 per barrel would result in a ceiling test impairment. Based on informati on contained in your Form 10 -Q for the quarterly period ended

William R. Broaddrick Ring Energy, Inc. December 29, 2015 Page 2

September 30, 2015, it appears that prices during 2015 have been significantly below that level. However, we note that you have not recorded a ceiling test impairment. Explain to us how you ha ve concluded that no ceiling test charge was necessary for any of the interim periods in 2015. As part of your response, provide reasonably detailed summaries of your ceiling test calculations for each of the quarters of 2015. Clearly describe all signif icant assumptions underlying your calculations, including those related to reserve volumes, prices and costs. Describe the reasons for any changes between the assumptions used in each of your quarterly tests during 2015 and the corresponding assumptions u nderlying the calculation of your proved reserves as of December 31, 2014.

Management’s Discussion and Analysis of Financial Condition and Results of Operations

Disclosure of Contractual Obligations, page 17

3. We note your presentation of a table of contractual obligations. While this disclosure is not required in reports on Form 10 -Q, if you elect to provide it voluntarily, update it to reflect amounts through the end of the period reported in the Form 10 -Q. In this regard, we note that your presentation here does not reflect amounts outstanding under your credit facility as of September 30, 2015.

Controls and Procedures

Changes in internal control over financial reporting, page 21

4. Please clarify whether there were changes in your internal control over financial reporting that materially affected or are reasonably likely to materially affect your internal control over financial reporting. Refer to Item 308(c) of Regulation S -K.

We urge all persons who ar e 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.

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 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.

William R. Broaddrick Ring Energy, Inc. December 29, 2015 Page 3

You may contact Sandy Eisen at (202) 551-3864 or me at (202) 551 -3489 if you have questions regarding comments on the financial statements and related matters.

Sincerely,
/s/ Brad Skinner

Show Raw Text
Mail Stop 4628
December 29 , 2015

William R. Broaddrick
Chief Financial Officer
Ring Energy, Inc.
901 West Wall St., 3rd Floor
Midland, TX 79702

Re: Ring Energy, Inc
 Form 10 -Q for Fiscal Quarter  Ended
September 30, 2015
Filed November 9, 2015
File No. 1-36057

Dear Mr. Broaddrick :

We have reviewed your filing an d have the following comments.  In some of our
comments, we may ask you to provide us with information so we may better understand your
disclosure.

Please respond to these comments  within ten busine ss days by providing the requested
information or advis e us as soon as possible when you will respond.  If you do not believe our
comments apply to your facts and circums tances, please tell us why in your response.

After reviewing your response to these  comments, we may have  additional comments.

Form 10 -Q for Fiscal Quarter Ended September 30, 2015

Financial Statements

Note 1 – Basis of Presentation and Significant Accounting Policies

Oil and Gas Properties, page 9

1. You state here that you evaluate oil and gas properties for impairment at least annually.
Please tell us how your accounting policy complies with Regulation S -X, Rule 4 -
10(c)(4), which requi res a ceiling test to be performed each period, i.e. quarterly.

2. Disclosure on page 30 of your Form 10 -K for the year ended December 31, 2014
indicates that oil prices below $69.99 per barrel would result in a ceiling test impairment.
Based on informati on contained in your Form 10 -Q for the quarterly period ended

William R. Broaddrick
Ring Energy, Inc.
December 29, 2015
Page 2

 September 30, 2015, it appears that prices during 2015 have been significantly below that
level.  However, we note that you have not recorded a ceiling test impairment.  Explain to
us how you ha ve concluded that no ceiling test charge was necessary for any of the
interim periods in 2015.  As part of your response, provide reasonably detailed
summaries of your ceiling test calculations for each of the quarters of 2015.  Clearly
describe all signif icant assumptions underlying your calculations, including those related
to reserve volumes, prices and costs.  Describe the reasons for any changes between the
assumptions used in each of your quarterly tests during 2015 and the corresponding
assumptions u nderlying the calculation of your proved reserves as of December 31, 2014.

Management’s Discussion and Analysis of Financial Condition and Results of Operations

Disclosure of Contractual Obligations, page 17

3. We note your presentation of a table of contractual obligations.  While this disclosure is
not required in reports on Form 10 -Q, if you elect to provide it voluntarily, update it to
reflect amounts through the end of the period reported in the Form 10 -Q.  In this regard,
we note that your presentation here does not reflect amounts outstanding under your
credit facility as of September 30, 2015.

Controls and Procedures

Changes in internal control over financial reporting, page 21

4. Please clarify whether there were changes in your internal control over financial reporting
that materially affected or are reasonably likely to materially affect your internal control
over financial reporting.  Refer to Item 308(c) of Regulation S -K.

We urge all persons who ar e 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.

 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 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.

William R. Broaddrick
Ring Energy, Inc.
December 29, 2015
Page 3

You may contact Sandy Eisen  at (202) 551-3864  or me at (202) 551 -3489 if you have questions
regarding comments on the financial statements and related matters.

Sincerely,

 /s/ Brad Skinner

        Brad Skinner
Senior Assistant Chief Accountant
Office of Natural Resources