Correspondence 0001654954-23-001309 from American Resources Corp (AREC) (CIK 0001590715) (AREC)
American Resources Corp (AREC) (CIK 0001590715)
Date: Feb. 6, 2023 · CIK: 0001590715 · Accession: 0001654954-23-001309
AI Filing Summary & Sentiment
Referenced dates: December 6, 2022
Letter
arec_corresp.htm
January 13, 2023
Securities and Exchange Commission
Division of Corporation Finance
Office of Energy & Transportation
Regarding: Letter Dated December 6, 2022
Form 10-K/A for the fiscal year ended December 31, 2021
McCoy Elkhorn Coal LLC, page 5
2. We note your property location descriptions in this section and elsewhere are described generally, such as within a county or near a city or town. Please amend your filing and describe your property locations more precisely, e.g. providing a bearing and distance from a prominent landmark. See Item 1303(b)(2)(ii)(A) of Regulation S-K.
Response: We agree with the comment and have revised our filing accordingly.
3. We have reviewed your filing and found your ownership interest description was not specified or quantified. Please amend your filing and describe the type and amounts of your property interests, such as leased or owned by acreage amounts. See Item 1303(b)(2)(ii)(B) and (D) of Regulation S-K.
Response: We agree with the comment and have revised our filing accordingly.
4. We note your filing does not include maps for your Perry County Resources LLC and ERC Mining properties as required by Item 1303(b)(1) of Regulation S-K. Please provide
these maps in your amended filing.
Response: We agree with the comment relating to Perry County Resources LLC and have revised our filing accordingly. Regarding ERC Mining, the assets relating to ERC Mining have been written off and the permit is in reclamation status. The filing has been amended to add additional disclosure for this.
5. We note you have designated your Carnegie and E4-2 properties as material properties. Please amend your filing, locate these properties to within one mile, using a common coordinate system, such a latitude/longitude or section, township and range in your text, and provide appropriate maps. See Item 1304(b)(1)(i) of Regulation S-K.
Response: We agree with the comment and have revised our filing accordingly.
6. For your material properties, please modify your filing to provide a brief description of your mineral rights, leases or options with acreage, possession/termination provisions, and associated payments. See Items 1304(b)(1)(iii) of Regulation S-K.
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 arec_corresp.htm January 13, 2023 Securities and Exchange Commission Division of Corporation Finance Office of Energy & Transportation Regarding: Letter Dated December 6, 2022 Form 10-K/A for the fiscal year ended December 31, 2021 McCoy Elkhorn Coal LLC, page 5 2. We note your property location descriptions in this section and elsewhere are described generally, such as within a county or near a city or town. Please amend your filing and describe your property locations more precisely, e.g. providing a bearing and distance from a prominent landmark. See Item 1303(b)(2)(ii)(A) of Regulation S-K. Response: We agree with the comment and have revised our filing accordingly. 3. We have reviewed your filing and found your ownership interest description was not specified or quantified. Please amend your filing and describe the type and amounts of your property interests, such as leased or owned by acreage amounts. See Item 1303(b)(2)(ii)(B) and (D) of Regulation S-K. Response: We agree with the comment and have revised our filing accordingly. 4. We note your filing does not include maps for your Perry County Resources LLC and ERC Mining properties as required by Item 1303(b)(1) of Regulation S-K. Please provide these maps in your amended filing. Response: We agree with the comment relating to Perry County Resources LLC and have revised our filing accordingly. Regarding ERC Mining, the assets relating to ERC Mining have been written off and the permit is in reclamation status. The filing has been amended to add additional disclosure for this. 5. We note you have designated your Carnegie and E4-2 properties as material properties. Please amend your filing, locate these properties to within one mile, using a common coordinate system, such a latitude/longitude or section, township and range in your text, and provide appropriate maps. See Item 1304(b)(1)(i) of Regulation S-K. Response: We agree with the comment and have revised our filing accordingly. 6. For your material properties, please modify your filing to provide a brief description of your mineral rights, leases or options with acreage, possession/termination provisions, and associated payments. See Items 1304(b)(1)(iii) of Regulation S-K. Response: We agree with the comment and have revised our filing accordingly. Regards, Kirk P. Taylor, CPA Chief Financial Officer American Resources Corp 2