SEC Comment Letter for Rise Gold Corp. (RYES) (CIK 0001424864) (RYES) — Feb 28, 2017
Rise Gold Corp. (RYES) (CIK 0001424864)
Date: Feb. 28, 2017 · CIK: 0001424864 · Accession: 0000000000-17-006696
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 000-53848
Letter
Mail Stop 3561 February 28 , 2017 Via E -mail Cale Thomas Chief Financial Officer Rise Resources, Inc. 488-1090 West Georgia Street Vancouver, British Columbia, Canada V6E 3V7
Re: Rise Resources, Inc. Form 10-K for the Fiscal Year Ended July 31 , 2016 Filed October 31 , 2016 Form 10 -Q for the Quarterly Period Ended October 31, 2016 Filed on December 9, 2016 File No. 000-53848
Dear Mr . Thomas :
We have reviewed your filing 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 prov iding the requested information or adv ise 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 .
Form 10-K for the Fiscal Year Ended July 31 , 2016
Item 1. Business Description of Business Mineral Properties page 23
1. We note your disclosure of mineral resources on page 23 for an adjacent property and on page 28 for your Ron property. Only proven or probable reserves may be disclosed in filings with the United States Securities and Exchange Commission pursuant to the Instructions to Item 102 of Regulation S -K. Please remove these mineral resources.
2. We note your disclosure of historical explorat ion work. Please include in your disclosure a brief summary of your data verification and quality assurance procedures for
Cale Thomas Rise Resources, Inc. February 28 , 2017 Page 2
exploration work performed on your properties. If these processes have yet to be developed then include a statement to this effect in your disclosure.
Item 9A. Controls and Procedures, page 40
3. Please provide a conclusion regarding the effectiveness of your disclosure controls and procedures pursuant to Item 307 of Regulation S -K. In addition, provide management’s annual report on internal control over financial reporting pursuant to Item 308 of Regulation S -K.
Form 10 -Q for the Quarterly Period Ended October 31, 2016 Item 4. Controls and Procedures, page 7
4. Please provide a conclusion regarding the effectiveness of your disclosur e controls and procedures pursuant to Item 307 of Regulation S -K.
You may contact Steve Lo at (202) 551 -3394 or me at (202) 551 -3650 if you have questions regarding comments on the financial statements and related matters and John Coleman, Mining Engineer at (202) 551 -3610 regarding the engineering comments.
Sincerely,
/s/Craig Arakawa
Show Raw Text
Mail Stop 3561
February 28 , 2017
Via E -mail
Cale Thomas
Chief Financial Officer
Rise Resources, Inc.
488-1090 West Georgia Street
Vancouver, British Columbia, Canada V6E 3V7
Re: Rise Resources, Inc.
Form 10-K for the Fiscal Year Ended July 31 , 2016
Filed October 31 , 2016
Form 10 -Q for the Quarterly Period Ended October 31, 2016
Filed on December 9, 2016
File No. 000-53848
Dear Mr . Thomas :
We have reviewed your filing 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 prov iding the requested
information or adv ise 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 .
Form 10-K for the Fiscal Year Ended July 31 , 2016
Item 1. Business
Description of Business
Mineral Properties page 23
1. We note your disclosure of mineral resources on page 23 for an adjacent property and on
page 28 for your Ron property. Only proven or probable reserves may be disclosed in
filings with the United States Securities and Exchange Commission pursuant to the
Instructions to Item 102 of Regulation S -K. Please remove these mineral resources.
2. We note your disclosure of historical explorat ion work. Please include in your disclosure
a brief summary of your data verification and quality assurance procedures for
Cale Thomas
Rise Resources, Inc.
February 28 , 2017
Page 2
exploration work performed on your properties. If these processes have yet to be
developed then include a statement to this effect in your disclosure.
Item 9A. Controls and Procedures, page 40
3. Please provide a conclusion regarding the effectiveness of your disclosure controls and
procedures pursuant to Item 307 of Regulation S -K. In addition, provide management’s
annual report on internal control over financial reporting pursuant to Item 308 of
Regulation S -K.
Form 10 -Q for the Quarterly Period Ended October 31, 2016
Item 4. Controls and Procedures, page 7
4. Please provide a conclusion regarding the effectiveness of your disclosur e controls and
procedures pursuant to Item 307 of Regulation S -K.
You may contact Steve Lo at (202) 551 -3394 or me at (202) 551 -3650 if you have
questions regarding comments on the financial statements and related matters and John Coleman,
Mining Engineer at (202) 551 -3610 regarding the engineering comments.
Sincerely,
/s/Craig Arakawa
Craig Arakawa
Accounting Branch Chief
Office of Beverages, Apparel and
Mining