SEC Comment Letter for CMB.TECH NV (CMBT) (CIK 0001604481) (CMBT) — Nov 14, 2014
CMB.TECH NV (CMBT) (CIK 0001604481)
Date: Nov. 14, 2014 · CIK: 0001604481 · Accession: 0000000000-14-057213
AI Filing Summary & Sentiment
Reasoning
Letter
November 14 , 2014 Via E -mail Patrick Rodgers Chief Executive Officer Euronav NV De Gerlachekaai 20 2000 Antwerpen Belgium
Re: Euronav NV Amendment No. 1 to Registration Statement on Form F -1 Filed November 4 , 2014 File No. 333 -198625
Dear Mr. Rodgers:
We have reviewed your response to our prior comment letter to you dated September 22 , 2014 and have the following additional comments .
Notes to Condensed Consolidated Interim Financial Statements Note 4 – Significant Events, page F -8 1. We note the disclosure on page F -11 indicating that the Group cancelled the time charter out contract on the VLCC Maersk Hakone against a payment of U.S. $2.5 million on August 11, 2014. Please tell us and revise to disclose how this fee was accounted for in your consolidated statement of operations.
Note 10 – Earnings per share, page F -16 2. We note that the number of ordinary shares outstanding (basic) as at September 30, 2014, as reflected in the table at the top of page F -17 of 129,300,666 shares does not agree t o the weighted average number of shares reflected in the calculation of basic earnings per share for the nine months ended September 30, 2014 as disclosed on page F -16 of 112,238,388. Please reconcile and revise these disclosures.
Exhibit s 10.15 and 10.18
3. We note your response to our prior comment 5. It appears that Appendix 4 to these exhibits is missing certain conformed signatures. Please re -file or advise .
Patrick Rodgers Euronav NV November 14 , 2014 Page 2
You may contact Effie Simpson at (202) 551 -3346 or Linda Cvrkel, Accounting Branch Chief, at (202) 551 -3813 if you have questions regarding comments on the financial statements and related matters. Please contact Ada D. Sarmento at (202) 551 -3798 or me at (202) 551 -3210 with any other questions.
Sincerely,
/s/ Susan Block
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November 14 , 2014 Via E -mail Patrick Rodgers Chief Executive Officer Euronav NV De Gerlachekaai 20 2000 Antwerpen Belgium Re: Euronav NV Amendment No. 1 to Registration Statement on Form F -1 Filed November 4 , 2014 File No. 333 -198625 Dear Mr. Rodgers: We have reviewed your response to our prior comment letter to you dated September 22 , 2014 and have the following additional comments . Notes to Condensed Consolidated Interim Financial Statements Note 4 – Significant Events, page F -8 1. We note the disclosure on page F -11 indicating that the Group cancelled the time charter out contract on the VLCC Maersk Hakone against a payment of U.S. $2.5 million on August 11, 2014. Please tell us and revise to disclose how this fee was accounted for in your consolidated statement of operations. Note 10 – Earnings per share, page F -16 2. We note that the number of ordinary shares outstanding (basic) as at September 30, 2014, as reflected in the table at the top of page F -17 of 129,300,666 shares does not agree t o the weighted average number of shares reflected in the calculation of basic earnings per share for the nine months ended September 30, 2014 as disclosed on page F -16 of 112,238,388. Please reconcile and revise these disclosures. Exhibit s 10.15 and 10.18 3. We note your response to our prior comment 5. It appears that Appendix 4 to these exhibits is missing certain conformed signatures. Please re -file or advise . Patrick Rodgers Euronav NV November 14 , 2014 Page 2 You may contact Effie Simpson at (202) 551 -3346 or Linda Cvrkel, Accounting Branch Chief, at (202) 551 -3813 if you have questions regarding comments on the financial statements and related matters. Please contact Ada D. Sarmento at (202) 551 -3798 or me at (202) 551 -3210 with any other questions. Sincerely, /s/ Susan Block Susan Block Attorney -Advisor cc: Via E -mail Gary J. Wolfe, Esq.