SEC Comment Letter for Navios Maritime Partners L.P. (NMM) (CIK 0001415921) (NMM) — Jul 10, 2015
Navios Maritime Partners L.P. (NMM) (CIK 0001415921)
Date: July 10, 2015 · CIK: 0001415921 · Accession: 0000000000-15-036266
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 001-33811
Letter
July 10, 2015 Mr. Efstratios Desypris Chief Financial Officer Navios Maritime Partners L.P. 85 Akti Miaouli Street Piraeus, Greece 185 38
Re: Navios Maritime Partners L.P. Form 20-F for the Year Ended December 31, 2014 Filed March 13, 2015 File No. 001-33811
Dear Mr. Desypris :
We have limited our review of your filing to the financial statements and related disclosures and have the following comment . In our comment , we may ask you to provide us with information so we may better understand your disclosure.
Please respond to this comment 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 comment applies to your facts and circumstances, please tell us why in your response.
After reviewing your response to these comments, we may have additional comments.
Item 5. Operating and Financial Review and Pro spects
F. Contractual Obligations and Contingencies, Page 63
1. Please revise to include estimated interest payments on outstanding long -term debt obligations. Because the table is aimed at increasing transparency of cash flows, it appears that interest pa yments should be disclosed. You may either disclose estimated interest payments in the table of contractual obligations or in a footnote to the table. Additionally, please disclose any assumptions used to arrive at the estimated amounts based on variable rates. Please refer to Item 5.F of the General Instructions to Form 20-F.
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.
Mr. Efstratios Desypris Navios Maritime Partners L.P. July 10, 2015 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 Melissa Gilmore at (202) 551 -3777 or me at (202) 551 -3379 with any questions.
Sincerely,
/s/ Melissa Raminpour
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July 10, 2015 Mr. Efstratios Desypris Chief Financial Officer Navios Maritime Partners L.P. 85 Akti Miaouli Street Piraeus, Greece 185 38 Re: Navios Maritime Partners L.P. Form 20-F for the Year Ended December 31, 2014 Filed March 13, 2015 File No. 001-33811 Dear Mr. Desypris : We have limited our review of your filing to the financial statements and related disclosures and have the following comment . In our comment , we may ask you to provide us with information so we may better understand your disclosure. Please respond to this comment 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 comment applies to your facts and circumstances, please tell us why in your response. After reviewing your response to these comments, we may have additional comments. Item 5. Operating and Financial Review and Pro spects F. Contractual Obligations and Contingencies, Page 63 1. Please revise to include estimated interest payments on outstanding long -term debt obligations. Because the table is aimed at increasing transparency of cash flows, it appears that interest pa yments should be disclosed. You may either disclose estimated interest payments in the table of contractual obligations or in a footnote to the table. Additionally, please disclose any assumptions used to arrive at the estimated amounts based on variable rates. Please refer to Item 5.F of the General Instructions to Form 20-F. 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. Mr. Efstratios Desypris Navios Maritime Partners L.P. July 10, 2015 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 Melissa Gilmore at (202) 551 -3777 or me at (202) 551 -3379 with any questions. Sincerely, /s/ Melissa Raminpour Melissa Raminpour Branch Chief