SEC Comment Letter 0000000000-24-009421 to Metals Acquisition Ltd (MTAL) (CIK 0001950246)
Metals Acquisition Ltd (MTAL) (CIK 0001950246)
Date: Aug. 16, 2024 · CIK: 0001950246 · Accession: 0000000000-24-009421
AI Filing Summary & Sentiment
File numbers found in text: 001-41722
Letter
August 16, 2024 Morné Engelbrecht Chief Financial Officer Metals Acquisition Ltd 3rd Floor, 44 Esplanade, St. Helier, Jersey, JE4 9WG Re:Metals Acquisition Ltd Form 20-F for the Fiscal Year Ended December 31, 2023 Filed March 28, 2024 File No. 001-41722 Dear Morné Engelbrecht: We have reviewed your August 6, 2024 response to our comment letter and have the following comment. 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. Unless we note otherwise, any references to prior comments are to comments in our July 23, 2024 letter. Form 20-F for the Fiscal Year Ended December 31, 2023 Filed March 28, 2024 Item 4. Information on the Company, page 38 Based on the information provided in response to comment 1 we note that the total mineral resources have increased from 3.5 million tonnes at 5.6% copper at December 31, 2022 to 7.8 million tonnes at 5.2% copper at December 31, 2023, and the the total mineral reserves, reported exclusive of mineral resources, have increased from 7.9 million tonnes at 4% copper at December 31, 2022 to 14.6 million tonnes at 3.2% copper at December 31, 2023.
The increase in mineral resources and mineral reserves represents a material change in the quantities of mineral resources and reserves at December 31,2023 as compared to December 31, 2022. Therefore please file an amended Form 20-F for the fiscal year ended December 31, 2023 that includes these changes, along with the information that you have included in response to prior comments 1 to 3 and a reconciliation comparing your 1.
August 16, 2024 Page 2 resources and reserves as of the two fiscal year ends presented and a related discussion which addresses each instruction as required by Item 1304(e) of Regulation S-K.
Additionally a registrant must file a technical report summary as an exhibit to a Commission filing when there is a material change in the mineral reserves or mineral resources from the last technical report summary, as required by Item 1302(b)(2)(i) of Regulation S-K. Please file a revised technical report summary. The filing of the updated technical report summary should be accompanied with the disclosure required by Item 1304(f)(1) of Regulation S-K in the individual property section of your Form 20-F. Please contact John Coleman at 202-551-3610 or Craig Arakawa at 202-551-3650 if you have questions regarding comments on the financial statements and related matters. Sincerely, Division of Corporation Finance Office of Energy & Transportation
Show Raw Text
August 16, 2024
Morné Engelbrecht
Chief Financial Officer
Metals Acquisition Ltd
3rd Floor, 44 Esplanade,
St. Helier, Jersey, JE4 9WG
Re:Metals Acquisition Ltd
Form 20-F for the Fiscal Year Ended December 31, 2023
Filed March 28, 2024
File No. 001-41722
Dear Morné Engelbrecht:
We have reviewed your August 6, 2024 response to our comment letter and have the
following comment.
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. Unless we
note otherwise, any references to prior comments are to comments in our July 23, 2024 letter.
Form 20-F for the Fiscal Year Ended December 31, 2023 Filed March 28, 2024
Item 4. Information on the Company, page 38
Based on the information provided in response to comment 1 we note that the total
mineral resources have increased from 3.5 million tonnes at 5.6% copper at December 31,
2022 to 7.8 million tonnes at 5.2% copper at December 31, 2023, and the the total mineral
reserves, reported exclusive of mineral resources, have increased from 7.9 million tonnes
at 4% copper at December 31, 2022 to 14.6 million tonnes at 3.2% copper at December
31, 2023.
The increase in mineral resources and mineral reserves represents a material change in the
quantities of mineral resources and reserves at December 31,2023 as compared to
December 31, 2022. Therefore please file an amended Form 20-F for the fiscal year ended
December 31, 2023 that includes these changes, along with the information that you have
included in response to prior comments 1 to 3 and a reconciliation comparing your 1.
August 16, 2024
Page 2
resources and reserves as of the two fiscal year ends presented and a related discussion
which addresses each instruction as required by Item 1304(e) of Regulation S-K.
Additionally a registrant must file a technical report summary as an exhibit to a
Commission filing when there is a material change in the mineral reserves or mineral
resources from the last technical report summary, as required by Item 1302(b)(2)(i) of
Regulation S-K. Please file a revised technical report summary. The filing of the updated
technical report summary should be accompanied with the disclosure required by Item
1304(f)(1) of Regulation S-K in the individual property section of your Form 20-F.
Please contact John Coleman at 202-551-3610 or Craig Arakawa at 202-551-3650 if you
have questions regarding comments on the financial statements and related matters.
Sincerely,
Division of Corporation Finance
Office of Energy & Transportation