Trends in Sec Comment Letters on Regulation S-K 1300
Abstract
Mining companies registered with the SEC were required to comply with Regulation S-K 1300 for their annual report covering the first fiscal year ending on or after January 1, 2021. Consequently, most mining registrants filed their first S-K 1300 compliant disclosures in 2022. the US Securities & Exchange Commission (SEC), as part of its disclosure review program, has been issuing comment letters in response to these filings. This paper presents an overview of the trends in these comment letters. the authors reviewed comment letters retrieved from the SEC's EDGAR database based on Standard Industrial Classification (SIC) Codes that cover mining, the content of the comment letter (whether it references S-K 1300 or not), the names of SEC staff listed in the comment letters, and other criteria. the analysis shows the SEC staff's reviews have been comprehensive covering the breadth of S-K 1300 and eliciting compliance with the rule. the staff through their comments are eliciting all the disclosures required by S-K 1300 and are not allowing registrants to substitute disclosures based on other standards for S-K 1300 disclosures. It is important, however, not to over generalize as the comments are based on the particular context.
Recommended Citation
K. Awuah-Offei and J. B. Offei, "Trends in Sec Comment Letters on Regulation S-K 1300," SME Annual Conference and Expo 2023, Society for Mining, Metallurgy and Exploration, Jan 2023.
Department(s)
Mining Engineering
International Standard Book Number (ISBN)
978-171387236-8
Document Type
Article - Conference proceedings
Document Version
Citation
File Type
text
Language(s)
English
Rights
© 2025 Society for Mining, Metallurgy and Exploration, All rights reserved.
Publication Date
01 Jan 2023
