SEC Comment Letter 0000000000-24-007870 to Triple Flag Precious Metals Corp. (TFPM) (CIK 0001829726) (TFPM)
Triple Flag Precious Metals Corp. (TFPM) (CIK 0001829726)
Date: July 11, 2024 · CIK: 0001829726 · Accession: 0000000000-24-007870
AI Filing Summary & Sentiment
File numbers found in text: 001-41484
Letter
July 11, 2024 Sheldon Vanderkooy Chief Financial Officer Triple Flag Precious Metals Corp. TD Canada Trust Tower 161 Bay Street, Suite 4535 Toronto, Ontario, Canada M5J 2S1 Re:Triple Flag Precious Metals Corp. Form 40-F for the Fiscal Year Ended December 31, 2023 File No. 001-41484 Dear Sheldon Vanderkooy: We have limited our review of your filing to the financial statements and related disclosures and have the following comments. Please respond to this letter 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 a comment applies to your facts and circumstances, please tell us why in your response. After reviewing your response to this letter, we may have additional comments. Form 40-F for the Fiscal Year Ended December 31, 2023 Exhibit 99.2 3. Summary of material accounting policies e. Mineral interests, page 14 Please tell us and revise your filing to disclose in greater detail the type(s) of mineral resources (measured, indicated and/or inferred) that are included in your estimated recoverable resources. Please discuss the following: •The percentage of measured, indicated, and inferred resources that you include in the portion of resources expected to be converted as reserves. •The history of converting resources into proven and probable reserves. If inferred resources have been included, separately address the history of converting inferred resources into reserves. •If inferred resources have been included, please discuss your basis for their inclusion and how you compensated for the lower level of confidence in estimating tonnage, grade and mineral content.1.
July 11, 2024 Page 2 •Disclose the number of years of historical data that you use to estimate your projected rates of converting resources to proven and probable reserves. Discuss why you believe this historical data is indicative of future conversion rates. 2.You disclose that in cases where life of mine models and publicly available mineral reserves and resources statements are not available, you base depletion on the your best estimate of the volumes to be delivered under the contract. Please tell us how you determine these volume estimates, identifying the underlying mineral interests that are depleted using these estimates and the amounts capitalized related to these interests. 3.You indicate that you record costs related to your exploration stage projects in accordance with IFRS 6. Please tell us and revise your filing to separately disclose the amount of exploration and evaluation assets that are recognized in your financial statements. Reference is made to paragraphs 23 through 25 of IFRS 6. In closing, 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. Please contact Frank Knapp at 202-551-3805 or Jennifer Monick at 202-551-3295 with any questions. Sincerely, Division of Corporation Finance Office of Real Estate & Construction cc:Christopher Bornhorst
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July 11, 2024
Sheldon Vanderkooy
Chief Financial Officer
Triple Flag Precious Metals Corp.
TD Canada Trust Tower
161 Bay Street, Suite 4535
Toronto, Ontario, Canada M5J 2S1
Re:Triple Flag Precious Metals Corp.
Form 40-F for the Fiscal Year Ended December 31, 2023
File No. 001-41484
Dear Sheldon Vanderkooy:
We have limited our review of your filing to the financial statements and related
disclosures and have the following comments.
Please respond to this letter 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 a
comment applies to your facts and circumstances, please tell us why in your response.
After reviewing your response to this letter, we may have additional comments.
Form 40-F for the Fiscal Year Ended December 31, 2023
Exhibit 99.2
3. Summary of material accounting policies
e. Mineral interests, page 14
Please tell us and revise your filing to disclose in greater detail the type(s) of mineral
resources (measured, indicated and/or inferred) that are included in your estimated
recoverable resources. Please discuss the following:
•The percentage of measured, indicated, and inferred resources that you include in the
portion of resources expected to be converted as reserves.
•The history of converting resources into proven and probable reserves. If inferred
resources have been included, separately address the history of converting inferred
resources into reserves.
•If inferred resources have been included, please discuss your basis for their inclusion
and how you compensated for the lower level of confidence in estimating tonnage,
grade and mineral content.1.
July 11, 2024
Page 2
•Disclose the number of years of historical data that you use to estimate your projected
rates of converting resources to proven and probable reserves. Discuss why you
believe this historical data is indicative of future conversion rates.
2.You disclose that in cases where life of mine models and publicly available mineral
reserves and resources statements are not available, you base depletion on the your best
estimate of the volumes to be delivered under the contract. Please tell us how you
determine these volume estimates, identifying the underlying mineral interests that are
depleted using these estimates and the amounts capitalized related to these interests.
3.You indicate that you record costs related to your exploration stage projects in accordance
with IFRS 6. Please tell us and revise your filing to separately disclose the amount of
exploration and evaluation assets that are recognized in your financial statements.
Reference is made to paragraphs 23 through 25 of IFRS 6.
In closing, 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.
Please contact Frank Knapp at 202-551-3805 or Jennifer Monick at 202-551-3295 with
any questions.
Sincerely,
Division of Corporation Finance
Office of Real Estate & Construction
cc:Christopher Bornhorst