SEC Comment Letter for Nutrien Ltd. (NTR) (CIK 0001725964) (NTR) — Apr 30, 2020
Nutrien Ltd. (NTR) (CIK 0001725964)
Date: April 30, 2020 · CIK: 0001725964 · Accession: 0000000000-20-003708
AI Filing Summary & Sentiment
File numbers found in text: 001-38336
Letter
United States securities and exchange commission logo April 30, 2020 Pedro Farah Chief Financial Officer Nutrien Ltd. Suite 200 122 1st Avenue South Saskatoon, Saskatchewan, Canada S7K 7G3 Re:Nutrien Ltd. Form 40-F for the Fiscal Year Ended December 31, 2019 Filed February 28, 2020 File No. 001-38336 Dear Mr. Farah: 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. Form 40-F for the Fiscal Year Ended December 31, 2019 Exhibit 99.1 Mineral Projects, page 47 1.We note that you do not disclose mineral reserve estimates for your phosphate mines. Please provide these reserve estimates or tell us why disclosure of these amounts is not necessary. 2.We note that you provide disclosure of the tonnages that can depleted from the mineral reserve estimates for the Allan, Cory, Lanigan, and Rocanville reserve estimates such that a current mineral reserve estimate corresponding to your fiscal year end may be determined. Please tell us why a similar depletable tonnage is not disclosed for the Vanscoy mineral reserve estimate.
FirstName LastNamePedro Farah Comapany NameNutrien Ltd. April 30, 2020 Page 2 FirstName LastName Pedro Farah Nutrien Ltd. April 30, 2020 Page 2 We remind you that the company and its management are responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the staff. You may contact John Coleman at 202-551-3610 or Craig Arakawa at 202-551-3650 if you have questions regarding comments. Sincerely, Division of Corporation Finance Office of Life Sciences
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United States securities and exchange commission logo
April 30, 2020
Pedro Farah
Chief Financial Officer
Nutrien Ltd.
Suite 200
122 1st Avenue South
Saskatoon, Saskatchewan, Canada
S7K 7G3
Re:Nutrien Ltd.
Form 40-F for the Fiscal Year Ended December 31, 2019
Filed February 28, 2020
File No. 001-38336
Dear Mr. Farah:
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.
Form 40-F for the Fiscal Year Ended December 31, 2019
Exhibit 99.1
Mineral Projects, page 47
1.We note that you do not disclose mineral reserve estimates for your phosphate mines.
Please provide these reserve estimates or tell us why disclosure of these amounts is not
necessary.
2.We note that you provide disclosure of the tonnages that can depleted from the mineral
reserve estimates for the Allan, Cory, Lanigan, and Rocanville reserve estimates such that
a current mineral reserve estimate corresponding to your fiscal year end may be
determined. Please tell us why a similar depletable tonnage is not disclosed for the
Vanscoy mineral reserve estimate.
FirstName LastNamePedro Farah
Comapany NameNutrien Ltd.
April 30, 2020 Page 2
FirstName LastName
Pedro Farah
Nutrien Ltd.
April 30, 2020
Page 2
We remind you that the company and its management are responsible for the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action or absence of
action by the staff.
You may contact John Coleman at 202-551-3610 or Craig Arakawa at 202-551-3650 if
you have questions regarding comments.
Sincerely,
Division of Corporation Finance
Office of Life Sciences