SEC Comment Letter for Capital Clean Energy Carriers Corp. (CCEC) (CIK 0001392326) (CCEC) — Nov 13, 2014
Capital Clean Energy Carriers Corp. (CCEC) (CIK 0001392326)
Date: Nov. 13, 2014 · CIK: 0001392326 · Accession: 0000000000-14-056838
AI Filing Summary & Sentiment
File numbers found in text: 001-33373
Letter
November 13, 2014 Via E -mail Petros Christodoulou 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 Fiscal Year Ended December 31, 2013 Filed February 18, 2014 File No. 001-33373
Dear Mr. Chirstodoulou :
We have reviewed your filing and have the following comment . In our comment , we ask you to provide us with information so we may better understand your disclosure.
Please r espond to this letter within ten business days by providing any reque sted information . If you do not believe our comments apply to your facts and circumstances, please tell us why in y our response.
After reviewing the information you provide in response to these comments, we may have additional comments.
Notes to the Consolidated Financial Statements, F -8
Note 13. Partners’ Capital, page F -41
1. We note that certain holders of Class B Convertible Preferred Units converted 5,733,333 of their units into Common Units during 2013, presumably at the specified conversion price per share of $9. Please tell us how the conversion was recorded in greater detail and how the conversion was reporte d in the consolidated statement of changes in partners’ capital .
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 Exchang e 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.
Petros Christodoulou Capital Product Partners L.P. November 13, 2014 Page 2
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 Uni ted States.
You may contact Stephen Kim at 202-551-3291 or Doug Jones at 202-551-3309 if you have any questions.
Sincerely,
/s/ Andrew D. Mew
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November 13, 2014 Via E -mail Petros Christodoulou 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 Fiscal Year Ended December 31, 2013 Filed February 18, 2014 File No. 001-33373 Dear Mr. Chirstodoulou : We have reviewed your filing and have the following comment . In our comment , we ask you to provide us with information so we may better understand your disclosure. Please r espond to this letter within ten business days by providing any reque sted information . If you do not believe our comments apply to your facts and circumstances, please tell us why in y our response. After reviewing the information you provide in response to these comments, we may have additional comments. Notes to the Consolidated Financial Statements, F -8 Note 13. Partners’ Capital, page F -41 1. We note that certain holders of Class B Convertible Preferred Units converted 5,733,333 of their units into Common Units during 2013, presumably at the specified conversion price per share of $9. Please tell us how the conversion was recorded in greater detail and how the conversion was reporte d in the consolidated statement of changes in partners’ capital . 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 Exchang e 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. Petros Christodoulou Capital Product Partners L.P. November 13, 2014 Page 2 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 Uni ted States. You may contact Stephen Kim at 202-551-3291 or Doug Jones at 202-551-3309 if you have any questions. Sincerely, /s/ Andrew D. Mew For Lyn Shenk Branch Chief