SEC Comment Letter 0000000000-23-001649 to Loma Negra Compania Industrial Argentina Sociedad Anonima (LOMA)
Loma Negra Compania Industrial Argentina Sociedad Anonima
Date: Feb. 17, 2023 · CIK: 0001711375 · Accession: 0000000000-23-001649
AI Filing Summary & Sentiment
Show Raw Text
United States securities and exchange commission logo
February 17, 2023
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
Amendment No. 1 to Form 20-F for the Year Ended December 31, 2021
File No. 1-38262
Dear Marcos Gradin:
We have reviewed your filing 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 these comments 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
comments apply to your facts and circumstances, please tell us why in your response.
After reviewing your response to these comments, we may have additional comments.
Amendment No. 1 to Form 20-F for the Year Ended December 31, 2021
Overview of Mineral Reserves, page 4
1.We reviewed your reserve disclosure and noted the sale price for your salable products,
which serve as a basis of your reserve determination, was not disclosed in your filing as
required the footnotes to Tables 1 and 2 of paragraph (b) for Item 1303 of Regulation S-
K. In addition, the metallurgical recoveries were not disclosed for your material
properties as required by Items 1304(d)(1) of Regulation S-K. Please modify your filing
and include these modification factors for each of your properties with your reserve tables.
Location and History, page 5
2.We note your individual material property disclosure beginning in this section. Please
modify your filing and locate each of your material properties within one mile, using an
easily recognizable coordinate system to comply with Item 1304(b)(1)(i) of Regulation S-
K.
FirstName LastNameMarcos Gradin
Comapany NameLoma Negra Compania Industrial Argentina Sociedad Anonima
February 17, 2023 Page 2
FirstName LastName
Marcos Gradin
Loma Negra Compania Industrial Argentina Sociedad Anonima
February 17, 2023
Page 2
Facilities, page 9
3.Please modify your filing and include the book value for your material property as
required by Item 1304(b)(2)(iii) of Regulation S-K.
Exhibit 96.1
La Pampita y Entorno Quarry, page 8
4.Please modify your filing to locate your property to within one-mile using an easily
recognizable coordinate system. In addition, please enlarge your maps and illustrations to
make them legible as required by Item 601(B)(96)(iii)(b)(3)(i) of Regulation S-K.
Exhibit 96.1
Geological Units involved in the project, page 14
5.Please modify your filing to provide a cross-section of the local geology as required by
Item 601(B)(96)(iii)(b)(6)(iii) of Regulation S-K.
Exhibit 96.1
Adequacy of the Test Data, page 26
6.We reviewed the mineral processing section of your technical report summary. Please
modify your filing to include the QP’s opinion on the adequacy of the data and state the
metallurgical recovery as required by Item 601(B)(96)(iii)(b)(10)(v) of Regulation S-K.
Exhibit 96.1
Reserves Estimation, page 30
7.We note you did not disclose a reserve price or metallurgical recovery for your reserve
estimates. Please state the price and recovery used to determine your reserves and
disclose, with particularity, the reasons this price was selected and any assumptions
underlying this selection. See Item 601(B)(96)(iii)(b)(12)(iii) of Regulation S-K.
Exhibit 96.1
Annual Production Rate, page 35
8.Please modify your technical report to provide the annual Life of Mine (LOM) production
schedule for your limestone and waste production as required by Item
601(B)(96)(iii)(b)(13) of Regulation S-K.
FirstName LastNameMarcos Gradin
Comapany NameLoma Negra Compania Industrial Argentina Sociedad Anonima
February 17, 2023 Page 3
FirstName LastName
Marcos Gradin
Loma Negra Compania Industrial Argentina Sociedad Anonima
February 17, 2023
Page 3
Exhibit 96.1
Market Studies, page 40
9.We note you did not disclose a commodity price forecast in the section. Please modify
your technical report to disclose your cement price projections and the basis for your
commodity price forecast as used in your economic evaluation as required by Item
601(B)(96)(iii)(b)(16) of Regulation S-K.
Exhibit 96.1 A
Capital and Operating Costs, page 43
10.We note you did not disclose an accuracy estimate with your capital and operating cost
estimates as required by Item 601(B)(96)(iii)(b)(18)(i) of Regulation S-K. Please modify
your filing to include your accuracy estimate and discuss how the annual operating costs
in this section relate to the operating costs presented in the economic analysis.
Exhibit 96.1 A
Economic Viability, page 44
11.Please modify your technical report to include the annual mined material tonnage in your
cash flow analysis as required by Item 601(B)(96)(iii)(b)(19) of Regulation S-K.
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