SEC Comment Letter 0000000000-23-006363 to RING ENERGY, INC. (REI)
RING ENERGY, INC.
Date: June 13, 2023 · CIK: 0001384195 · Accession: 0000000000-23-006363
AI Filing Summary & Sentiment
File numbers found in text: 001-36057
Letter
United States securities and exchange commission logo June 13, 2023 Travis T. Thomas Chief Financial Officer Ring Energy, Inc. 1725 Hughes Landing Blvd., Suite 900 The Woodlands, TX 77380 Re:Ring Energy, Inc. Form 10-K for Fiscal Year Ended December 31, 2022 Form 8-K filed May 4, 2023 Response dated June 1, 2023 File No. 001-36057 Dear Travis T. Thomas: We have reviewed your June 1, 2023 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 May 16, 2023 letter. Form 8-K filed May 4, 2023 Exhibit 99.1 First Quarter 2023 Highlights and Recent Key Items, page 1 1.We note your response to prior comment 9 and your proposed disclosure of the reconciliation necessary to derive the Leverage Ratio as set forth in your Second Amended and Restated Credit Agreement dated as of August 31, 2022. To the extent that this Leverage Ratio is a material covenant in your credit agreement, please revise your discussion to include the amount or limit required for compliance with the covenant and the actual or reasonably likely effects of compliance or non-compliance with the covenant on the company's financial condition and liquidity. Refer to Question 102.09 of the Non- GAAP Compliance and Disclosure Interpretations.
FirstName LastNameTravis T. Thomas Comapany NameRing Energy, Inc. June 13, 2023 Page 2 FirstName LastName Travis T. Thomas Ring Energy, Inc. June 13, 2023 Page 2 You may contact Jennifer O'Brien, Staff Accountant, at 202-551-3721 or Shannon Buskirk, Staff Accountant, at 202-551-3717 if you have any questions. Sincerely, Division of Corporation Finance Office of Energy & Transportation
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United States securities and exchange commission logo
June 13, 2023
Travis T. Thomas
Chief Financial Officer
Ring Energy, Inc.
1725 Hughes Landing Blvd., Suite 900
The Woodlands, TX 77380
Re:Ring Energy, Inc.
Form 10-K for Fiscal Year Ended December 31, 2022
Form 8-K filed May 4, 2023
Response dated June 1, 2023
File No. 001-36057
Dear Travis T. Thomas:
We have reviewed your June 1, 2023 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
May 16, 2023 letter.
Form 8-K filed May 4, 2023
Exhibit 99.1
First Quarter 2023 Highlights and Recent Key Items, page 1
1.We note your response to prior comment 9 and your proposed disclosure of
the reconciliation necessary to derive the Leverage Ratio as set forth in your Second
Amended and Restated Credit Agreement dated as of August 31, 2022. To the extent that
this Leverage Ratio is a material covenant in your credit agreement, please revise your
discussion to include the amount or limit required for compliance with the covenant and
the actual or reasonably likely effects of compliance or non-compliance with the covenant
on the company's financial condition and liquidity. Refer to Question 102.09 of the Non-
GAAP Compliance and Disclosure Interpretations.
FirstName LastNameTravis T. Thomas
Comapany NameRing Energy, Inc.
June 13, 2023 Page 2
FirstName LastName
Travis T. Thomas
Ring Energy, Inc.
June 13, 2023
Page 2
You may contact Jennifer O'Brien, Staff Accountant, at 202-551-3721 or Shannon
Buskirk, Staff Accountant, at 202-551-3717 if you have any questions.
Sincerely,
Division of Corporation Finance
Office of Energy & Transportation