SEC Comment Letter for Loma Negra Compania Industrial Argentina Sociedad Anonima (LOMA) (CIK 0001711375) (LOMA) — Oct 17, 2017
Loma Negra Compania Industrial Argentina Sociedad Anonima (LOMA) (CIK 0001711375)
Date: Oct. 17, 2017 · CIK: 0001711375 · Accession: 0000000000-17-036753
AI Filing Summary & Sentiment
Reasoning
Letter
Mail Stop 4631 October 17, 2017 Marcos Gradin Chief Financial Officer Loma Negra Compañía Industrial Argentina Sociedad Anónima Reconquista 1088, 7th Floor Ciudad Autónoma de Buenos Aires, Argentina Zip Code C1003ABQ
Re: Loma Negra Compañía Industrial Argentina Sociedad Anónima Amendment No. 2 to Re gistration Statement on Form F -1 Filed October 12, 2017 File No. 333 -220347
Dear Mr. Gradin :
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 a nd 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 6, 2017 letter .
General
1. Please note that your preliminary prospectus must include a bona fide price range. In general, we believe that a bona fide price range means a range of no more than 20% for offerings of greater than $10 per share.
Voting Rights, page 207
2. We reissue the first bullet of comment 1. Please make clea r any timelines by which you will endeavor to provide notice to the depositary. We note paragraphs 2.10 and 5.6 of Exhibit 4.1.
Marcos Gradin Loma Negra Compañía Industrial Argentina Sociedad Anónima October 17, 2017 Page 2
Exhibit 5.1
3. Please have cou nsel revise or remove the assumption (g) in paragraph three of its opinion .
You may contact Dale Welcome, Staff Accountant , at (202) 551 -3865 or Kevin Stertzel, Staff Accountant, at (202) 551 -3723 if you have questions regarding comments on the financial statements and related matters. Please contact Sergio Chinos, Staff Attorney , at (202) 551 -7844 or me at (202) 551 -3754 with any other questions.
Sincerely,
/s/ Asia Timmons -Pierce, for
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Mail Stop 4631 October 17, 2017 Marcos Gradin Chief Financial Officer Loma Negra Compañía Industrial Argentina Sociedad Anónima Reconquista 1088, 7th Floor Ciudad Autónoma de Buenos Aires, Argentina Zip Code C1003ABQ Re: Loma Negra Compañía Industrial Argentina Sociedad Anónima Amendment No. 2 to Re gistration Statement on Form F -1 Filed October 12, 2017 File No. 333 -220347 Dear Mr. Gradin : 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 a nd 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 6, 2017 letter . General 1. Please note that your preliminary prospectus must include a bona fide price range. In general, we believe that a bona fide price range means a range of no more than 20% for offerings of greater than $10 per share. Voting Rights, page 207 2. We reissue the first bullet of comment 1. Please make clea r any timelines by which you will endeavor to provide notice to the depositary. We note paragraphs 2.10 and 5.6 of Exhibit 4.1. Marcos Gradin Loma Negra Compañía Industrial Argentina Sociedad Anónima October 17, 2017 Page 2 Exhibit 5.1 3. Please have cou nsel revise or remove the assumption (g) in paragraph three of its opinion . You may contact Dale Welcome, Staff Accountant , at (202) 551 -3865 or Kevin Stertzel, Staff Accountant, at (202) 551 -3723 if you have questions regarding comments on the financial statements and related matters. Please contact Sergio Chinos, Staff Attorney , at (202) 551 -7844 or me at (202) 551 -3754 with any other questions. Sincerely, /s/ Asia Timmons -Pierce, for Pamela A. Long Assistant Director Office of Manufacturing and Construction cc: John R. Vetterli, Esq. John P. Guzman, Esq.