Correspondence 0001654954-23-003447 from American Resources Corp (AREC) (CIK 0001590715) (AREC)
American Resources Corp (AREC) (CIK 0001590715)
Date: March 23, 2023 · CIK: 0001590715 · Accession: 0001654954-23-003447
AI Filing Summary & Sentiment
Referenced dates: December 6, 2022
Letter
corresp_arec8-ka
March 23, 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
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. Please
confirm 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. Additionally, we have submitted a draft of the 2022 earnings 8-K for review.
Regards,
Kirk P.
Taylor, CPA
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CORRESP 1 filename1.htm corresp_arec8-ka March 23, 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. Please confirm 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. Additionally, we have submitted a draft of the 2022 earnings 8-K for review. Regards, Kirk P. Taylor, CPA Chief Financial Officer American Resources Corp