SEC Comment Letter 0000000000-24-008518 to CVR PARTNERS, LP (UAN) (CIK 0001425292) (UAN)
CVR PARTNERS, LP (UAN) (CIK 0001425292)
Date: July 26, 2024 · CIK: 0001425292 · Accession: 0000000000-24-008518
AI Filing Summary & Sentiment
File numbers found in text: 001-35120
Letter
July 26, 2024 Dane J. Neumann Chief Financial Officer CVR PARTNERS, LP 2277 Plaza Drive, Suite 500 Sugarland TX 77479 Re:CVR PARTNERS, LP Form 10-K for the Year Ended December 31, 2023 Filed February 21, 2024 File No. 001-35120 Dear Dane J. Neumann: We have limited our review of your filing to the financial statements and related disclosures and have the following comment. Please respond to this letter 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 a comment applies to your facts and circumstances, please tell us why in your response. After reviewing your response to this letter, we may have additional comments. Form 10-K for the Year Ended December 31, 2023 Non-GAAP Reconciliations, page 46 1.We note your non-GAAP reconciliation of Available Cash for Distribution includes three reconciling items labelled as current (reserves) adjustments for operating/investing/financing activities and that you have included footnote disclosure that describes various elements included in each of the three reconciling items. Please address the following: •Expand your footnote disclosure to further describe the elements labelled as other future operating needs, other future investing activities and other future financing needs. •For each of the items described in the footnotes, quantify each element included in the adjustment.
July 26, 2024 Page 2 In closing, we remind you that the company and its management are responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the staff. Please contact Brian McAllister at 202-551-3341 or Craig Arakawa at 202-551-3650 with any questions. Sincerely, Division of Corporation Finance Office of Energy & Transportation
Show Raw Text
July 26, 2024
Dane J. Neumann
Chief Financial Officer
CVR PARTNERS, LP
2277 Plaza Drive, Suite 500
Sugarland TX 77479
Re:CVR PARTNERS, LP
Form 10-K for the Year Ended December 31, 2023
Filed February 21, 2024
File No. 001-35120
Dear Dane J. Neumann:
We have limited our review of your filing to the financial statements and related
disclosures and have the following comment.
Please respond to this letter 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 a
comment applies to your facts and circumstances, please tell us why in your response.
After reviewing your response to this letter, we may have additional comments.
Form 10-K for the Year Ended December 31, 2023
Non-GAAP Reconciliations, page 46
1.We note your non-GAAP reconciliation of Available Cash for Distribution includes three
reconciling items labelled as current (reserves) adjustments for
operating/investing/financing activities and that you have included footnote disclosure
that describes various elements included in each of the three reconciling items. Please
address the following:
•Expand your footnote disclosure to further describe the elements labelled as other
future operating needs, other future investing activities and other future financing
needs.
•For each of the items described in the footnotes, quantify each element included in
the adjustment.
July 26, 2024
Page 2
In closing, we remind you that the company and its management are responsible for the
accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or
absence of action by the staff.
Please contact Brian McAllister at 202-551-3341 or Craig Arakawa at 202-551-3650 with
any questions.
Sincerely,
Division of Corporation Finance
Office of Energy & Transportation