SEC Comment Letter for Ramaco Resources, Inc. (METC, METCB, METCL) (CIK 0001687187) (METC) — May 29, 2018
Ramaco Resources, Inc. (METC, METCB, METCL) (CIK 0001687187)
Date: May 29, 2018 · CIK: 0001687187 · Accession: 0000000000-18-016464
AI Filing Summary & Sentiment
Letter
Mail Stop: 3561 May 29 , 2018 Via E -Mail Mr. Marc Solochek Chief Financial Officer Ramaco Resources, Inc. 250 West Main Street, Suite 1800 Lexington, Kentucky 40507
Re: Ramaco Resources, Inc. Form 10-K for the Fiscal Year Ended December 31 , 2017 Filed March 21 , 2018 File No. 001 -38003
Dear Mr. Solochek :
We have reviewed your filing an d have the following comment s. In our comment s, we may ask you to provide us with information so we may better understand your disclosure.
Please respond to this letter 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 yo ur facts and circumstances, please tell us why in your response.
After reviewing your response to the comment s, we may have additional comments.
Form 10 -K for the Fiscal Year Ended December 31, 2017 Management’s Discussion and Analysis Results of Operations Year Ended December 31, 2017 compared to Year Ended December 31, 2016, page 43
1. We note you present the non-GAAP measure average cash cost per ton sold here, at page 11 of your Form 10 -Q for the three months ended March 31, 2018 and in your pres s release included at Exhibit 99.1 to your Form 8 -K filed on May 15 , 2018. We note that you also present the non -GAAP measure average cash margin per ton in your press release. Please provide the disclosures required by Item 10(e)(1)(i) of Regulation S -K in each of your respective filings or tell us why this guidance does not apply to you .
Marc Solochek May 29 , 2018 Page 2 Financial Statements Consolidated Statements of Operations, page 50
2. We note you present pro forma basic and diluted loss per share for the year ended Dece mber 31, 2 017 on the face of your statement of operations. Please tell us why this presentation is appropriate, citing the applicable U.S. GAAP literature that supports your view.
3. Please present basic and diluted per share amounts on the face of your statement of operations to comply with ASC 260 -10-45-2 or tell us why this literature does not apply to you. Please also make corresponding changes to your earnings per share disclosures at Note 13 .
Note 2 – Summary of Signific ant Accounting Policies Property, Plant and Equipment, page 55
4. Please expand your policy disclosure related to your mine development costs to clarify when capitalization of these costs begins.
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 Joanna Lam at (202) 551 -3476 or me at (202) 551 -3650 if you have quest ions regarding comments on the financial statements and related matters.
Sincerely,
/s/Craig Arakawa
Show Raw Text
Mail Stop: 3561
May 29 , 2018
Via E -Mail
Mr. Marc Solochek
Chief Financial Officer
Ramaco Resources, Inc.
250 West Main Street, Suite 1800
Lexington, Kentucky 40507
Re: Ramaco Resources, Inc.
Form 10-K for the Fiscal Year Ended December 31 , 2017
Filed March 21 , 2018
File No. 001 -38003
Dear Mr. Solochek :
We have reviewed your filing an d have the following comment s. In our comment s, we
may ask you to provide us with information so we may better understand your disclosure.
Please respond to this letter 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 yo ur facts and circumstances, please tell us why in your response.
After reviewing your response to the comment s, we may have additional comments.
Form 10 -K for the Fiscal Year Ended December 31, 2017
Management’s Discussion and Analysis
Results of Operations
Year Ended December 31, 2017 compared to Year Ended December 31, 2016, page 43
1. We note you present the non-GAAP measure average cash cost per ton sold here, at page
11 of your Form 10 -Q for the three months ended March 31, 2018 and in your pres s
release included at Exhibit 99.1 to your Form 8 -K filed on May 15 , 2018. We note that
you also present the non -GAAP measure average cash margin per ton in your press
release. Please provide the disclosures required by Item 10(e)(1)(i) of Regulation S -K in
each of your respective filings or tell us why this guidance does not apply to you .
Marc Solochek
May 29 , 2018
Page 2
Financial Statements
Consolidated Statements of Operations, page 50
2. We note you present pro forma basic and diluted loss per share for the year ended
Dece mber 31, 2 017 on the face of your statement of operations. Please tell us why this
presentation is appropriate, citing the applicable U.S. GAAP literature that supports your
view.
3. Please present basic and diluted per share amounts on the face of your statement of
operations to comply with ASC 260 -10-45-2 or tell us why this literature does not apply
to you. Please also make corresponding changes to your earnings per share disclosures at
Note 13 .
Note 2 – Summary of Signific ant Accounting Policies
Property, Plant and Equipment, page 55
4. Please expand your policy disclosure related to your mine development costs to clarify
when capitalization of these costs begins.
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 Joanna Lam at (202) 551 -3476 or me at (202) 551 -3650 if you have
quest ions regarding comments on the financial statements and related matters.
Sincerely,
/s/Craig Arakawa
Craig Arakawa
Branch Chief
Office of Beverages, Apparel, and
Mining