Correspondence 0001654954-23-000629 from American Resources Corp (AREC) (CIK 0001590715) (AREC)
American Resources Corp (AREC) (CIK 0001590715)
Date: Jan. 20, 2023 · CIK: 0001590715 · Accession: 0001654954-23-000629
AI Filing Summary & Sentiment
Referenced dates: December 6, 2022
Letter
americanresourcescorp8-ka
January 20, 2023
Securities and Exchange Commission
Division of Corporation Finance
Office of Energy & Transportation
Regarding: Letter Dated December 6, 2022
Form 8-K filed on August 15, 2022
Form 8-K filed on August 15, 2022
Reconciliation of Adjusted EBITDA to Amounts Reported Under U.S. GAAP, page 8 1. We note your response to comment 11. We continue to believe that your adjustment to exclude mine development costs is inconsistent with the guidance in Question 100.01 of the Non-GAAP Financial Measures Compliance and Disclosure Interpretations. Pleaseconfirm to us that you will no longer include the adjustment in any non-GAAP financial measures and revise to present your measure in accordance with Item 10(e) of Regulation
S-X and Regulation G.
Response: We agree with the comment and have revised our filing accordingly.
Regards,
Kirk P.
Taylor, CPA
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CORRESP 1 filename1.htm americanresourcescorp8-ka January 20, 2023 Securities and Exchange Commission Division of Corporation Finance Office of Energy & Transportation Regarding: Letter Dated December 6, 2022 Form 8-K filed on August 15, 2022 Form 8-K filed on August 15, 2022 Reconciliation of Adjusted EBITDA to Amounts Reported Under U.S. GAAP, page 8 1. We note your response to comment 11. We continue to believe that your adjustment to exclude mine development costs is inconsistent with the guidance in Question 100.01 of the Non-GAAP Financial Measures Compliance and Disclosure Interpretations. Pleaseconfirm to us that you will no longer include the adjustment in any non-GAAP financial measures and revise to present your measure in accordance with Item 10(e) of Regulation S-X and Regulation G. Response: We agree with the comment and have revised our filing accordingly. Regards, Kirk P. Taylor, CPA Chief Financial Officer American Resources Corp