SEC Comment Letter for Capital Clean Energy Carriers Corp. (CCEC) (CIK 0001392326) (CCEC) — Sep 5, 2014
Capital Clean Energy Carriers Corp. (CCEC) (CIK 0001392326)
Date: Sept. 5, 2014 · CIK: 0001392326 · Accession: 0000000000-14-044591
AI Filing Summary & Sentiment
Letter
UNITED STATES SECURITIES AND EXCHANGE COMMISSION WASHINGTON, D.C. 20549 DIVISION OF CORPORATION FINANCE September 4 , 2014 Via E-mail Ioannis E. Lazaridis Chief Executive Officer and Chief Financial Officer Capital Product Partners L.P. 3 Iassonos Street Piraeus 18537 Greece
Re: Capital Product Partners L .P. Form 20-F for the Fiscal Year Ended December 31 , 2013 Filed February 18 , 2014 File No. 1-33373
Dear M r. Lazaridis :
We have limited our review of your filing to your contacts with countries that have been identified as state sponsors of terrorism, and we have the following comment . Our review with respect to this issue does not preclude further review by the Assistant Director group with respect to other issues. In our comment , we ask you to provide us with informat ion so we may better understand your disclosure.
Please respond to this letter within ten business days by providing the requested information, or by advising us when you will provide the requested response. If you do not believe our comment applies to yo ur facts and circumstances, please tell us why in your response.
After reviewing the information you provide in response to th is comment , we may have additional comments.
Risk Factors , page 1 0 Our vessels may call on ports located in countries that are subject to restrictions and sanctions…, page 34
1. You state that in 2013 none of your vessels made port calls in Cuba or Syria, but you make no statement about port calls in Sudan. Please tell us whether any of your vessels made port calls in Sudan.
Ioannis E. Lazaridis Capital Product Partners L.P. September 4 , 2014 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 compa ny and its management are in possession of all facts relating to the company’s disclosure, they are responsible for the accuracy and adequacy of the disclosures they have made.
In responding to our comment , please provide a written statement from the c ompany 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 respec t 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.
Please contact Jennifer Hardy, Special Counsel, at (202) 551 -3767 or me at (202) 551 - 3470 if you have any questions about the comment or our review.
Sincerely,
/s/ Cecilia Blye
Show Raw Text
UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549
DIVISION OF
CORPORATION FINANCE
September 4 , 2014
Via E-mail
Ioannis E. Lazaridis
Chief Executive Officer and Chief Financial Officer
Capital Product Partners L.P.
3 Iassonos Street
Piraeus
18537 Greece
Re: Capital Product Partners L .P.
Form 20-F for the Fiscal Year Ended December 31 , 2013
Filed February 18 , 2014
File No. 1-33373
Dear M r. Lazaridis :
We have limited our review of your filing to your contacts with countries that have been
identified as state sponsors of terrorism, and we have the following comment . Our review with
respect to this issue does not preclude further review by the Assistant Director group with respect
to other issues. In our comment , we ask you to provide us with informat ion so we may better
understand your disclosure.
Please respond to this letter within ten business days by providing the requested
information, or by advising us when you will provide the requested response. If you do not
believe our comment applies to yo ur facts and circumstances, please tell us why in your
response.
After reviewing the information you provide in response to th is comment , we may have
additional comments.
Risk Factors , page 1 0
Our vessels may call on ports located in countries that are subject to restrictions and sanctions…,
page 34
1. You state that in 2013 none of your vessels made port calls in Cuba or Syria, but you
make no statement about port calls in Sudan. Please tell us whether any of your vessels
made port calls in Sudan.
Ioannis E. Lazaridis
Capital Product Partners L.P.
September 4 , 2014
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 compa ny and its management are
in possession of all facts relating to the company’s disclosure, they are responsible for the
accuracy and adequacy of the disclosures they have made.
In responding to our comment , please provide a written statement from the c ompany
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 respec t 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.
Please contact Jennifer Hardy, Special Counsel, at (202) 551 -3767 or me at (202) 551 -
3470 if you have any questions about the comment or our review.
Sincerely,
/s/ Cecilia Blye
Cecilia Blye, Chief
Office of Global Security Risk
cc: Andrew Mew
Assistant Director (Acting)
Division of Corporation Finance