SEC Comment Letter 0000000000-23-012027 to Osisko Gold Royalties LTD (OR) (CIK 0001627272) (OR)
Osisko Gold Royalties LTD (OR) (CIK 0001627272)
Date: Nov. 3, 2023 · CIK: 0001627272 · Accession: 0000000000-23-012027
AI Filing Summary & Sentiment
File numbers found in text: 001-37814
Letter
United States securities and exchange commission logo November 3, 2023 Frédéric Ruel Chief Financial Officer Osisko Gold Royalties Ltd 1100 Avenue des Canadiens-de-Montréal Suite 300 Montreal, Québec H3B 2S2 Re:Osisko Gold Royalties Ltd Form 40-F for the Year Ended December 31, 2022 40-F filed March 30, 2023 File No. 001-37814 Dear Frédéric Ruel: We have reviewed your filing and have the following comment. Please respond to this letter 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 a comment applies to your facts and circumstances, please tell us why in your response. After reviewing your response to this letter, we may have additional comments. Form 40-F for the Year Ended December 31, 2022 Exhibit 99.2. Consolidated Financial Statements Notes to the Consolidated Financial Statements Note 31. Deconsolidation of Osisko Development and discontinued operations, page 59 1.We note you deconsolidated Osisko Development effective September 30, 2022, following certain changes made to your investment agreement with Osisko Development. Please further clarify the changes made to the investment agreement that resulted in your decision to deconsolidate Osisko Development as of September 30, 2022. In this regard, we note that you continued to consolidate Osisko Development in your June 30, 2022 interim financial statements despite carrying a reduced ownership in this entity of 44.1% at that time. Please clearly explain why you believe the changes in the investment agreement resulted in a loss of control in accordance with paragraphs 7 and 8 of IFRS 10.
FirstName LastNameFrédéric Ruel Comapany NameOsisko Gold Royalties Ltd November 3, 2023 Page 2 FirstName LastName Frédéric Ruel Osisko Gold Royalties Ltd November 3, 2023 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. Please contact Myra Moosariparambil at 202-551-3796 or Craig Arakawa at 202-551- 3650 if you have questions regarding comments on the financial statements and related matters. Sincerely, Division of Corporation Finance Office of Energy & Transportation
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United States securities and exchange commission logo
November 3, 2023
Frédéric Ruel
Chief Financial Officer
Osisko Gold Royalties Ltd
1100 Avenue des Canadiens-de-Montréal
Suite 300
Montreal, Québec
H3B 2S2
Re:Osisko Gold Royalties Ltd
Form 40-F for the Year Ended December 31, 2022
40-F filed March 30, 2023
File No. 001-37814
Dear Frédéric Ruel:
We have reviewed your filing and have the following comment.
Please respond to this letter 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 a
comment applies to your facts and circumstances, please tell us why in your response.
After reviewing your response to this letter, we may have additional comments.
Form 40-F for the Year Ended December 31, 2022
Exhibit 99.2. Consolidated Financial Statements
Notes to the Consolidated Financial Statements
Note 31. Deconsolidation of Osisko Development and discontinued operations, page 59
1.We note you deconsolidated Osisko Development effective September 30, 2022,
following certain changes made to your investment agreement with Osisko
Development. Please further clarify the changes made to the investment agreement that
resulted in your decision to deconsolidate Osisko Development as of September 30,
2022. In this regard, we note that you continued to consolidate Osisko Development in
your June 30, 2022 interim financial statements despite carrying a reduced ownership in
this entity of 44.1% at that time. Please clearly explain why you believe the changes in the
investment agreement resulted in a loss of control in accordance with paragraphs 7 and 8
of IFRS 10.
FirstName LastNameFrédéric Ruel
Comapany NameOsisko Gold Royalties Ltd
November 3, 2023 Page 2
FirstName LastName
Frédéric Ruel
Osisko Gold Royalties Ltd
November 3, 2023
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.
Please contact Myra Moosariparambil at 202-551-3796 or Craig Arakawa at 202-551-
3650 if you have questions regarding comments on the financial statements and related matters.
Sincerely,
Division of Corporation Finance
Office of Energy & Transportation