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SEC Comment Letter 0000000000-22-013587 to Ramaco Resources, Inc. (METC)

Ramaco Resources, Inc.
Date: Dec. 16, 2022 · CIK: 0001687187 · Accession: 0000000000-22-013587

AI Filing Summary & Sentiment

File numbers found in text: 333-267152

Date
December 16, 2022
Author
FirstName LastName
Form
UPLOAD
Company
Ramaco Resources, Inc.

Letter

United States securities and exchange commission logo December 16, 2022 Randall W. Atkins Chairman and Chief Executive Officer Ramaco Resources, Inc. 250 West Main Street, Suite 1900 Lexington, Kentucky 40507

Re: Ramaco Resources, Inc. Amendment No. 2 to Registration Statement on Form S-1 Filed November 23, File No. 333-267152

Dear Randall W. Atkins:

We have reviewed your amended registration statement 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 this letter by amending your registration statement and providing the requested information. If you do not believe our comments apply to your facts and circumstances or do not believe an amendment is appropriate, please tell us why in your response.

After reviewing any amendment to your registration statement and the information you provide in response to these comments, we may have additional comments. Unless we note otherwise, our references to prior comments are to comments in our October 31, 2022 letter.

Amendment No. 2 to Registration Statement on Form S-1

Pro Forma Cash Available For Dividend For Year Ending December 31, 2022 and 2023, page 4

1. Revise to discuss why you lowered your pro forma revenue projections for the periods ended December 31, 2022 and 2023, and discuss any known trends in either prices or production volumes that are impacting your pro forma revenue projections. Estimated Cash Available for Dividends for the Years Ending December 31, 2022 and 2023, page 40

2. We note your revisions in response to prior comment 9 and reissue the comment in part. It appears that the presentation continues to provide information on an annual basis. As you intend to pay specific quarterly dividends, we believe that you should expand your Randall W. Atkins Ramaco Resources, Inc. December 16, 2022 Page 2 disclosure to provide the presentation on a quarterly basis, including your estimated cash available for distribution on a quarterly basis and the related assumptions. You may contact Robert Babula, Staff Accountant, at 202-551-3339 or Gus Rodriguez, Accounting Branch Chief, at 202-551-3752 if you have questions regarding comments on the financial statements and related matters. You may contact Ken Schuler, Mining Engineer, at 202-551-3718 if you have questions regarding engineering comments. Please contact Irene Barberena-Meissner, Staff Attorney, at 202-551-6548 or Loan Lauren Nguyen, Legal Branch Chief, at 202-551-3642 with any other questions.

Sincerely,
FirstName LastNameRandall W. Atkins
Division of
Corporation Finance
Comapany NameRamaco Resources, Inc.
Office of Energy &
Transportation
December 16, 2022 Page 2
cc: Matthew R. Pacey, P.C.
FirstName LastName

Show Raw Text
<DOCUMENT>
<TYPE>TEXT-EXTRACT
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<FILENAME>filename2.txt
<TEXT>
United States securities and exchange commission logo

                             December 16, 2022

       Randall W. Atkins
       Chairman and Chief Executive Officer
       Ramaco Resources, Inc.
       250 West Main Street, Suite 1900
       Lexington, Kentucky 40507

                                                        Re: Ramaco Resources,
Inc.
                                                            Amendment No. 2 to
Registration Statement on Form S-1
                                                            Filed November 23,
2022
                                                            File No. 333-267152

       Dear Randall W. Atkins:

             We have reviewed your amended registration statement 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 this letter by amending your registration
statement and providing the
       requested information. If you do not believe our comments apply to your
facts and
       circumstances or do not believe an amendment is appropriate, please tell
us why in your
       response.

              After reviewing any amendment to your registration statement and
the information you
       provide in response to these comments, we may have additional comments.
Unless we note
       otherwise, our references to prior comments are to comments in our
October 31, 2022 letter.

       Amendment No. 2 to Registration Statement on Form S-1

       Pro Forma Cash Available For Dividend For Year Ending December 31, 2022
and 2023, page 4

   1.                                                   Revise to discuss why
you lowered your pro forma revenue projections for the periods
                                                        ended December 31, 2022
and 2023, and discuss any known trends in either prices
                                                        or production volumes
that are impacting your pro forma revenue projections.
       Estimated Cash Available for Dividends for the Years Ending December 31,
2022 and 2023,
       page 40

   2.                                                   We note your revisions
in response to prior comment 9 and reissue the comment in part.
                                                        It appears that the
presentation continues to provide information on an annual basis. As
                                                        you intend to pay
specific quarterly dividends, we believe that you should expand your
 Randall W. Atkins
Ramaco Resources, Inc.
December 16, 2022
Page 2
      disclosure to provide the presentation on a quarterly basis, including
your estimated cash
      available for distribution on a quarterly basis and the related
assumptions.
        You may contact Robert Babula, Staff Accountant, at 202-551-3339 or Gus
Rodriguez,
Accounting Branch Chief, at 202-551-3752 if you have questions regarding
comments on the
financial statements and related matters. You may contact Ken Schuler, Mining
Engineer, at
202-551-3718 if you have questions regarding engineering comments. Please
contact Irene
Barberena-Meissner, Staff Attorney, at 202-551-6548 or Loan Lauren Nguyen,
Legal Branch
Chief, at 202-551-3642 with any other questions.

                                                           Sincerely,
FirstName LastNameRandall W. Atkins
                                                           Division of
Corporation Finance
Comapany NameRamaco Resources, Inc.
                                                           Office of Energy &
Transportation
December 16, 2022 Page 2
cc:       Matthew R. Pacey, P.C.
FirstName LastName
</TEXT>
</DOCUMENT>