RE: On the connection between mine feasibility studies, valuation, and impairment analysis

In November 2021, I posted a blog post about the connection between feasibility studies, valuation, and impairment analysis. I recently came across a comment letter by SEC staff that, I believe illustrates this connection. In this post, I wanted to quickly point out how this comment letter illustrates this connection and the fact that the SEC staff are on watch for issues such as these.

Continue reading “RE: On the connection between mine feasibility studies, valuation, and impairment analysis”

On the connection between mine feasibility studies, valuation, and impairment analysis

Most mining engineers are taught how to do mine feasibility studies in school but not all are familiar with property valuation and impairment tests. However, valuation and impairment analysis are also key aspects of the mining business that mining engineers should familiarize themselves with as they develop in their careers. In this post, I’m going to try to explain these terms, show the relationships between them, and discuss the role of mining engineers (and mine engineering work) in these.

Continue reading “On the connection between mine feasibility studies, valuation, and impairment analysis”

Now Clarified: SEC’s Regulation S-K 1300’s Compliance Timeline

When the Securities & Exchange Commission (SEC) passed its new mining property disclosure rules (Regulation S-K 1300) it set January 1, 2021 as the compliance date. Specifically, the SEC required that companies with material mining operations “must comply with the final rule amendments for the first fiscal year beginning on or after January 1, 2021.” While the compliance date for a company’s annual report has been clear from the beginning, the implications for when a company needs to file a registration statement within its “first fiscal year beginning on or after January 1, 2021” that requires disclosures of exploration results, resources and reserves have not been that obvious. The SEC, in guidance issued in April 2019, clarified circumstances under which disclosures of exploration results, resources and reserves in registration statements prior to the first annual report that is S-K 1300 complaint do not have to comply with S-K 1300. In this post, I will do my best to explain this to mining professionals who are not attorneys.

Continue reading “Now Clarified: SEC’s Regulation S-K 1300’s Compliance Timeline”

Was the SEC Encouraging Companies to use External QPs in S-K 1300?

Since the US Securities & Exchange Commission (SEC) passed its new mining property disclosure rules, I have heard many suggest that the SEC would prefer mining companies to use external professionals (i.e. consultants) as qualified persons (QPs) instead of their own employees. Such people cite the fact that the Commission, in the rules, allowed a third-party firm (i.e. a consulting company) to sign a technical report summary (TRS) and provide written consent on behalf of its employees who prepare the TRS. They point to the fact that the rules do not provide the same allowance for employees. This is simply not true and I will attempt to explain the Commission’s reasoning for arriving at this position in this post.

Continue reading “Was the SEC Encouraging Companies to use External QPs in S-K 1300?”