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SEC Comment Letter 0000000000-22-012455 to Loma Negra Compania Industrial Argentina Sociedad Anonima (LOMA)

Loma Negra Compania Industrial Argentina Sociedad Anonima
Date: Nov. 17, 2022 · CIK: 0001711375 · Accession: 0000000000-22-012455

AI Filing Summary & Sentiment

Sentiment
Urgency
Document Type
Confidence
SEC Posture
Company Posture

Summary

Reasoning

Date
November 17, 2022
Author
Marcos Gradin
Form
UPLOAD
Company
Loma Negra Compania Industrial Argentina Sociedad Anonima

Letter

United States securities and exchange commission logo November 17, 2022 Marcos Gradin Chief Financial Officer Loma Negra Compania Industrial Argentina Sociedad Anonima Cecilia Grierson 355 , 4th Floor Zip Code C1107CPG – Ciudad Autónoma de Buenos Aires Republic of Argentina Re:Loma Negra Compania Industrial Argentina Sociedad Anonima Form 20-F for the Year Ended December 31, 2021 Response dated November 2, 2022 File No. 1-38262 Dear Marcos Gradin: We have reviewed your November 2, 2022 response to our comment letter and have the following comment. In our comment, we may ask you to provide us with information so we may better understand your disclosure. Please respond to this comment 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 our comment applies to your facts and circumstances, please tell us why in your response. After reviewing your response to this comment, we may have additional comments. Unless we note otherwise, our references to prior comments are to comments in our October 19, 2022 letter. Form 20-F for the Year Ended December 31, 2021 General 1.We have read your response to comment one noting that you have re-assessed your conclusion on effectiveness of your disclosure controls and procedures and that you believe that they were effective as of December 31, 2021. We continue to consider the omitted disclosures and information required to comply with SK 1300 to be material and do not agree with your assessment. Please revise to state that your disclosures controls and procedures were not effective as of December 31, 2021 in your amended Form 20-F.

FirstName LastNameMarcos Gradin Comapany NameLoma Negra Compania Industrial Argentina Sociedad Anonima November 17, 2022 Page 2 FirstName LastName Marcos Gradin Loma Negra Compania Industrial Argentina Sociedad Anonima November 17, 2022 Page 2 If you have questions regarding mining comments, please contact Ken Schuler, Mine Engineer at (202) 551-3718 or Craig Arakawa at (202) 551-3650. You may contact Mindy Hooker at (202) 551-3732 or Kevin Stertzel at (202) 551-3723 with any other questions. Sincerely, Division of Corporation Finance Office of Manufacturing

Show Raw Text
United States securities and exchange commission logo
November 17, 2022
Marcos Gradin
Chief Financial Officer
Loma Negra Compania Industrial Argentina Sociedad Anonima
Cecilia Grierson 355 , 4th Floor
Zip Code C1107CPG – Ciudad Autónoma de Buenos Aires
Republic of Argentina
Re:Loma Negra Compania Industrial Argentina Sociedad Anonima
Form 20-F for the Year Ended December 31, 2021
Response dated November 2, 2022
File No. 1-38262
Dear Marcos Gradin:
            We have reviewed your November 2, 2022 response to our comment letter and have the
following comment.  In our comment, we may ask you to provide us with information so we may
better understand your disclosure.
            Please respond to this comment 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 our
comment applies to your facts and circumstances, please tell us why in your response.
            After reviewing your response to this comment, we may have additional
comments.  Unless we note otherwise, our references to prior comments are to comments in our
October 19, 2022 letter.
Form 20-F for the Year Ended December 31, 2021
General
1.We have read your response to comment one noting that you have re-assessed your
conclusion on effectiveness of your disclosure controls and procedures and that you
believe that they were effective as of December 31, 2021.   We continue to consider the
omitted disclosures and information required to comply with SK 1300 to be material and
do not agree with your assessment.  Please revise to state that your disclosures controls
and procedures were not effective as of December 31, 2021 in your amended Form 20-F.

 FirstName LastNameMarcos Gradin
 Comapany NameLoma Negra Compania Industrial Argentina Sociedad Anonima
 November 17, 2022 Page 2
 FirstName LastName
Marcos Gradin
Loma Negra Compania Industrial Argentina Sociedad Anonima
November 17, 2022
Page 2
            If you have questions regarding mining comments, please contact Ken Schuler, Mine
Engineer at (202) 551-3718 or Craig Arakawa at (202) 551-3650. You may contact Mindy
Hooker at (202) 551-3732 or Kevin Stertzel at (202) 551-3723 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing