SEC Comment Letter for A-Mark Precious Metals, Inc. (AMRK) (CIK 0001591588) (GOLD) — Jan 10, 2020
A-Mark Precious Metals, Inc. (AMRK) (CIK 0001591588)
Date: Jan. 10, 2020 · CIK: 0001591588 · Accession: 0000000000-20-000269
AI Filing Summary & Sentiment
File numbers found in text: 001-36347
Letter
January 10, 2020 Kathleen Simpson-Taylor Chief Financial Officer A-Mark Precious Metals, Inc. 2121 Rosecrans Ave., Suite 6300 El Segundo, CA 90245 Re:A-Mark Precious Metals, Inc. Form 10-K for the Fiscal Year Ended June 30, 2019 Filed September 16, 2019 File No. 001-36347 Dear Ms. Simpson-Taylor: 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 providing the requested information or advise 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 June 30, 2019 Item 8. Consolidated Financial Statements and Supplementary Data Note 14. Financing Agreements Liability on Borrowed Metals, page 86 1.Please disclose the specific line item(s) on the balance sheets that reflect the corresponding metals referred to with regard to the liabilities recorded as well as the amount of the corresponding metals included within each line item(s). Item 15. Exhibits and Financial Statement Schedules, page 96 2.We note that the Form 10-K is incorporated by reference in Form S-8 filed May 18, 2017. Please revise to file the consent of your independent registered public accounting firm. Please refer to Item 601(b)(23) of Regulation S-K.
FirstName LastNameKathleen Simpson-Taylor Comapany NameA-Mark Precious Metals, Inc. January 10, 2020 Page 2 FirstName LastName Kathleen Simpson-Taylor A-Mark Precious Metals, Inc. January 10, 2020 Page 2 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. You may contact Donna Di Silvio at 202-551-3202 or Bill Thompson at 202-551- 3344 if you have questions. Sincerely, Division of Corporation Finance Office of Trade & Services
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January 10, 2020
Kathleen Simpson-Taylor
Chief Financial Officer
A-Mark Precious Metals, Inc.
2121 Rosecrans Ave., Suite 6300
El Segundo, CA 90245
Re:A-Mark Precious Metals, Inc.
Form 10-K for the Fiscal Year Ended June 30, 2019
Filed September 16, 2019
File No. 001-36347
Dear Ms. Simpson-Taylor:
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 providing the requested
information or advise 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 June 30, 2019
Item 8. Consolidated Financial Statements and Supplementary Data
Note 14. Financing Agreements
Liability on Borrowed Metals, page 86
1.Please disclose the specific line item(s) on the balance sheets that reflect the
corresponding metals referred to with regard to the liabilities recorded as well as the
amount of the corresponding metals included within each line item(s).
Item 15. Exhibits and Financial Statement Schedules, page 96
2.We note that the Form 10-K is incorporated by reference in Form S-8 filed May 18, 2017.
Please revise to file the consent of your independent registered public accounting firm.
Please refer to Item 601(b)(23) of Regulation S-K.
FirstName LastNameKathleen Simpson-Taylor
Comapany NameA-Mark Precious Metals, Inc.
January 10, 2020 Page 2
FirstName LastName
Kathleen Simpson-Taylor
A-Mark Precious Metals, Inc.
January 10, 2020
Page 2
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.
You may contact Donna Di Silvio at 202-551-3202 or Bill Thompson at 202-551-
3344 if you have questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services