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
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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
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