SEC Comment Letter for RING ENERGY, INC. (REI) (CIK 0001384195) (REI) — Feb 25, 2019
RING ENERGY, INC. (REI) (CIK 0001384195)
Date: Feb. 25, 2019 · CIK: 0001384195 · Accession: 0000000000-19-003094
AI Filing Summary & Sentiment
File numbers found in text: 001-36057
Letter
February 21, 2019 William R. Broaddrick Chief Financial Officer Ring Energy, Inc. 901 West Wall St, 3rd Floor Midland, TX, 79702 Re:Ring Energy, Inc. Form 10-K for the Fiscal Year ended December 31, 2017 Response Dated February 8, 2019 File No. 001-36057 Dear Mr. Broaddrick: We have reviewed your February 8, 2019 response to our comment letter and 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 business days by providing the requested information or advise us as soon as possible when you will respond. If you do not believe our comments apply to your facts and circumstances, please tell us why in your response. After reviewing your response to these comments, we may have additional comments. Unless we note otherwise, our references to prior comments are to comments in our December 26, 2018 letter. Form 10-K for the Fiscal Year Ended December 31, 2017 Supplemental Information on Oil and Gas Producing Activities (Unaudited) Reserves Quantities Information, page F-22 1.We have read your response to comment 9 and note the illustration of your proposed future disclosure does not include separate disclosure of the figures for the proved developed and proved undeveloped reserves at the beginning of the first period shown, e.g. December 31, 2015. Revise your proposed future disclosure to meet the requirements pursuant to FASB ASC 932-235-50-4 and the illustration in Example 1 of FASB ASC 932-235-50-2. 2.We have read your response to comment 10 and note the illustration of your proposed future disclosure relates to the changes in the standardized measure of discounted future net cash flows pursuant to FASB ASC 932-235-35. Clarify for us that in the future you
FirstName LastNameWilliam R. Broaddrick Comapany NameRing Energy, Inc. February 21, 2019 Page 2 FirstName LastName William R. Broaddrick Ring Energy, Inc. February 21, 2019 Page 2 also intend to similarly revise your disclosure to include greater detail in the reconciliation of the changes in total proved reserves pursuant to the requirements in FASB ASC 932- 235-50-5 and in your presentation of the changes in proved undeveloped reserves as currently provided on page 17 pursuant to the requirements in Item 1203(b) of Regulation S-K. You may contact John Hodgin, Petroleum Engineer, at (202) 551-3699 or Brad Skinner, Senior Assistant Chief Accountant, at (202) 551-3489 if you have questions regarding the comments. Sincerely, Division of Corporation Finance Office of Natural Resources
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February 21, 2019
William R. Broaddrick
Chief Financial Officer
Ring Energy, Inc.
901 West Wall St, 3rd Floor
Midland, TX, 79702
Re:Ring Energy, Inc.
Form 10-K for the Fiscal Year ended December 31, 2017
Response Dated February 8, 2019
File No. 001-36057
Dear Mr. Broaddrick:
We have reviewed your February 8, 2019 response to our comment letter and 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 business days by providing the requested
information or advise us as soon as possible when you will respond. If you do not believe our
comments apply to your facts and circumstances, please tell us why in your response.
After reviewing your response to these comments, we may have additional
comments. Unless we note otherwise, our references to prior comments are to comments in our
December 26, 2018 letter.
Form 10-K for the Fiscal Year Ended December 31, 2017
Supplemental Information on Oil and Gas Producing Activities (Unaudited)
Reserves Quantities Information, page F-22
1.We have read your response to comment 9 and note the illustration of your proposed
future disclosure does not include separate disclosure of the figures for the proved
developed and proved undeveloped reserves at the beginning of the first period shown,
e.g. December 31, 2015. Revise your proposed future disclosure to meet the requirements
pursuant to FASB ASC 932-235-50-4 and the illustration in Example 1 of FASB ASC
932-235-50-2.
2.We have read your response to comment 10 and note the illustration of your proposed
future disclosure relates to the changes in the standardized measure of discounted future
net cash flows pursuant to FASB ASC 932-235-35. Clarify for us that in the future you
FirstName LastNameWilliam R. Broaddrick
Comapany NameRing Energy, Inc.
February 21, 2019 Page 2
FirstName LastName
William R. Broaddrick
Ring Energy, Inc.
February 21, 2019
Page 2
also intend to similarly revise your disclosure to include greater detail in the reconciliation
of the changes in total proved reserves pursuant to the requirements in FASB ASC 932-
235-50-5 and in your presentation of the changes in proved undeveloped reserves as
currently provided on page 17 pursuant to the requirements in Item 1203(b) of Regulation
S-K.
You may contact John Hodgin, Petroleum Engineer, at (202) 551-3699 or Brad Skinner,
Senior Assistant Chief Accountant, at (202) 551-3489 if you have questions regarding the
comments.
Sincerely,
Division of Corporation Finance
Office of Natural Resources