SEC Comment Letter for CMB.TECH NV (CMBT) (CIK 0001604481) (CMBT) — Dec 16, 2015
CMB.TECH NV (CMBT) (CIK 0001604481)
Date: Dec. 16, 2015 · CIK: 0001604481 · Accession: 0000000000-15-058193
AI Filing Summary & Sentiment
Reasoning
Letter
Mail Stop 3561 December 16 , 2015 Mr. Hugo De Stoop Chief Financial Officer Euronav NV Belgica H ouse Antwerp, 2000 Belgium
Re: Euronav NV Form 20-F for the Year Ended December 31, 2014 Filed April 3 0, 2015 File No. 001 -36810
Dear Mr. De Stoop :
We have reviewed your filing s 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 busine ss days by providing the requested information or advis e us as soon as possible when you will respond. If you do not believe our comments apply to your facts and circums tances, please tell us why in your response.
After reviewing your response to these comments, we may have additional comments.
Form 20-F for the year ended December 31, 2014
Note 25. Equity -accounted Investees, page F -59
1. Please provide us with your significance analysis under Rule 3 -09 of Regulation S -X for purposes of determining whether you are required to file audited financial statements for any of your 50% or less owned joint ventures. In this regard, it appears from your disclosure in Note 25 that your share of the profit in TI Africa Ltd and TI Asia Ltd may be significant to your consolidated income for the year ended December 31, 2014 under the guidance in Rule 3 -09 of Regulation S -X. Please advise.
We urge all persons who are responsible for the accuracy and adequacy of the disclosure in the filing to be certain that the filing includes the information the Securities Exchange Act of 1934 and all applicable Exchange Act rules require . Since the company and its management are in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy and adequacy of the disclosures they have made.
Mr. Hugo De Stoop Euronav NV December 16 , 2015 Page 2
In connection with responding to our comments, please p rovide, in writing, a statement from the company acknowledging that:
the company is responsible for the adequacy and accuracy of the disclosure in the filing;
staff comments or changes to disclosure in response to staff comments do not foreclose the Commission from taking any action with respect to the filing; and
the company may not assert staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.
You may contact Effie Simpson at (202) 551 -3346 , or in her absence, Claire Erlanger at (202) 551 -3301 if you have questions regarding comments on the financial statements and related matters. Please contact the undersigned, at (202) 551 -3750 with any other questions.
Sincerely,
/s/ Melissa Raminpour
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Mail Stop 3561
December 16 , 2015
Mr. Hugo De Stoop
Chief Financial Officer
Euronav NV
Belgica H ouse
Antwerp, 2000
Belgium
Re: Euronav NV
Form 20-F for the Year Ended December 31, 2014
Filed April 3 0, 2015
File No. 001 -36810
Dear Mr. De Stoop :
We have reviewed your filing s 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 busine ss days by providing the requested
information or advis e us as soon as possible when you will respond. If you do not believe our
comments apply to your facts and circums tances, please tell us why in your response.
After reviewing your response to these comments, we may have additional comments.
Form 20-F for the year ended December 31, 2014
Note 25. Equity -accounted Investees, page F -59
1. Please provide us with your significance analysis under Rule 3 -09 of Regulation S -X for
purposes of determining whether you are required to file audited financial statements for
any of your 50% or less owned joint ventures. In this regard, it appears from your
disclosure in Note 25 that your share of the profit in TI Africa Ltd and TI Asia Ltd may
be significant to your consolidated income for the year ended December 31, 2014 under
the guidance in Rule 3 -09 of Regulation S -X. Please advise.
We urge all persons who are responsible for the accuracy and adequacy of the disclosure
in the filing to be certain that the filing includes the information the Securities Exchange Act of
1934 and all applicable Exchange Act rules require . Since the company and its management are
in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy
and adequacy of the disclosures they have made.
Mr. Hugo De Stoop
Euronav NV
December 16 , 2015
Page 2
In connection with responding to our comments, please p rovide, in writing, a statement
from the company acknowledging that:
the company is responsible for the adequacy and accuracy of the disclosure in the filing;
staff comments or changes to disclosure in response to staff comments do not foreclose
the Commission from taking any action with respect to the filing; and
the company may not assert staff comments as a defense in any proceeding initiated by
the Commission or any person under the federal securities laws of the United States.
You may contact Effie Simpson at (202) 551 -3346 , or in her absence, Claire Erlanger at
(202) 551 -3301 if you have questions regarding comments on the financial statements and
related matters. Please contact the undersigned, at (202) 551 -3750 with any other questions.
Sincerely,
/s/ Melissa Raminpour
Melissa Raminpour
Branch Chief
Office of Transportation and Leisure