Mining
7 SEC staff comments and 3 disclosure examples from companies in this industry.
SIC codes included: 1000 Metal Mining, 1040 Gold and Silver Ores, 1400 Mining & Quarrying of Nonmetallic Minerals (No Fuels), 1090 Miscellaneous Metal Ores, 1221 Bituminous Coal & Lignite Surface Mining
Disclosure examples by topic
Mining: Related party transactions (ASC 850)1 exampleMining: Stock-based compensation (ASC 718)1 exampleMining: Leases (ASC 842)1 example
What the SEC staff asked companies in this industry
Oil, Gas & Mining (S-K 1200/1300) (4)Exhibits, Certifications & Signatures (3)Auditor & Audit Report (1)Non-GAAP: Adjustments & Labels (1)Non-GAAP: Reconciliation & Usefulness (1)
U.S. GOLD CORP. (USAU) · 2026-02-23 · · Comment 1 · and Properties, page 8 Awaiting / response not in dataset
Staff comment: Please disclose the commodity prices, cut-off grades, point of reference, and metallurgical recovery factors utilized in compiling your reserve estimates, along with the mineral reserve table on page 13, to comply with Item 1304(d)(1) of Regulation S-K. The Company acknowledges the Staff’s comment and proposes to revise its future disclosure to include the commodity prices, cut-off grades, point of reference, and metallurgical recovery factors utilized in compiling is reserve estimates, along with the mineral reserve table to comply with Item 1304(d)(1) of Regulation S-K. The revised version of the original disclosures shown on pages 12 to 13 of the Form 10-K showing the additional… letter →
U.S. GOLD CORP. (USAU) · 2026-02-23 · · Comment 2 · Degrees Agreed to revise
Staff comment: Please expand your disclosures to include a comparison of your estimates of mineral resources and your estimates of mineral reserves as of the end of the two most recent fiscal years, to include the percentages of change and an explanation for each type of change specified in Item 1304(e)(3) and (4) of Regulation S-K. letter →
Company response: #2 The Company acknowledges the Staff’s comment and proposes to expand its future disclosures to include a comparison of the Company’s estimates of mineral resources and estimates of mineral reserves as of the end of the two most recent fiscal years to include the percentages of change and an explanation for each type of change specified in Item 1304(e)(3) and (4) of Regulation S-K. The revised disclosure showing the additional information is set forth below. The Company proposes to include this additional level of detail in its disclosure in future filings, beginning with its Annual Report on Form 10-K for the fiscal year ending April 30, 2026. Variances between the Mineral Resources… response letter →
5E Advanced Materials, Inc. (FEAM, FEAV) · 2026-02-10 · Form 10-K for the Fiscal Year ended June 30, 2025 Filed September 29, 2025 · Comment 1 · Business Properties, page 7 Explained / pushed back
Staff comment: We note that you provide a comparison of your mineral resource estimates as of June 30, 2024 and June 30, 2025 in the second-to-last paragraph on page 26, and attribute a 27% increase in measured resource, a 350% increase in indicated resource, and a 93% decrease in inferred resource to increases in mineral tenure between periods. However, while the resource quantities reported in your annual filing are consistent with the estimates presented in the technical report summary, having changed materially between periods, there appear to be differences in the number of claims filed during the period. For example, disclosure on page 16 states that 28 lode claims were filed by the company in… letter →
Company response: The Company respectfully advises the Staff that the difference in the number of lode claims referenced in the Form 10-K as compared to the Company’s Preliminary Feasibility Study and Technical Report Summary dated August 7, 2025, with an effective date of August 4, 2025 (the “TRS”), reflects the different “as of” dates of those disclosures, rather than an inconsistency. • TRS effective date. The TRS (effective August 4, 2025) describes the Company’s mineral title and claim holdings as of that effective date. In January 2025, the Company filed 11 additional unpatented lode claims, and in August 2025, the Company filed 17 additional unpatented lode claims. As of August 4, 2025 (and as of June… response letter →
5E Advanced Materials, Inc. (FEAM, FEAV) · 2026-02-10 · Form 10-K for the Fiscal Year ended June 30, 2025 Filed September 29, 2025 · Comment 2 · reason for each class of resource along with the underlying numerical details. Responded
Staff comment: Please modify your disclosures as necessary to clarify whether the estimates of mineral resources disclosed in your filing are presented exclusive of mineral reserves although if this is not the case, please revise your disclosures to report the resources exclusive of reserves to comply with Item1304(d)(2) of Regulation S-K. Please also discuss this concern with the qualified persons involved in preparing the technical report summary as it may pertain to the accommodation for reporting mineral resources inclusive of mineral reserves in the technical report summary. If this approach is elected in preparing the technical report summary, the qualified persons must also report mineral resources… letter →
Company response: The Company acknowledges the Staff’s comment. The Company further acknowledges that the mineral resource estimates disclosed in the Form 10-K and presented in the TRS were not presented exclusive of mineral reserves. The Company has discussed the Staff’s comment with the QP involved in preparing the TRS, Mr. Kerr, and the QP agrees that future presentations will be revised to clearly and separately present (i) mineral reserves; and (ii) mineral resources exclusive of mineral reserves, in accordance with Item 1304(d)(2) of Regulation S-K and Item 601(b)(96)(iii)(B)(11)(ii) of Regulation S-K. response letter →
Linear Minerals Corp (LINMF) · 2026-02-06 · . Form 20-F for Fiscal Year Ended March 31, 2025 · Comment 1 · Exhibits 13-1 and 13-2, page 1 Awaiting / response not in dataset
Staff comment: Please amend your filing to include Section 906 certifications that reference the correct fiscal year end of March 31, 2025, rather than March 31, 2024. Refer to Item 601(b)(32) of Regulation S-K. letter →
Yinfu Gold Corp. (ELRE) · 2026-01-15 · Yinfu Gold Corporation Form 10-K for the Fiscal Year ended March 31, 2025 · Comment 1 · Report of Independent Registered Public Accounting Firm, page F-2 Awaiting / response not in dataset
Staff comment: Please amend the filing to have your auditor include an audit report that covers both periods presented in the audited financial statements in the format required by PCAOB Auditing Standard 3101. Refer to Rule 2-02 of Regulation S-X. letter →
Coeur Mining, Inc. (CDE) · 2025-12-12 · Form 10-Q for the Fiscal Quarter Ended September 30, 2025 Form 10-K for the Fiscal Year Ended December 31, 2024 Response · Comment 1 · Non-GAAP Financial Performance Measures, page 42 Agreed to revise
Staff comment: We note your response to prior comment 1 regarding your adjustment for “Acquired inventory purchase price” and do not agree with your conclusion. We continue to believe that this adjustment is inconsistent with Question 100.04 of the Compliance and Disclosure Interpretations on Non-GAAP Financial Measures. As such, please remove this adjustment from your non-GAAP measures, including Adjusted net income (loss), Adjusted EBITDA, and Adjusted costs applicable to sales. letter →
Company response: On behalf of Coeur Mining, Inc. (the “ Company ”) set forth below are responses to comments the staff (the “ Staff ”) of the Securities and Exchange Commission delivered by letter, dated December 12, 2025, with respect to the above referenced Form 10-K and Form 10-Q (the “ Comment Letter ”). The Company’s responses to the Staff’s comments are set forth below, with each paragraph numbered to correspond to the numbered comment in the Comment Letter. Form 10-K for the Fiscal Quarter Ended September 30, 2025 Non-GAAP Financial Performance Measures, page 42 Comment #1: We note your response to prior comment 1 regarding your adjustment for “Acquired inventory purchase price” and do not agree with… response letter →
Templates & resources
- AICPA & CIMA – SEC reporting resources (AICPA & CIMA · Professional body · Free / member)
- BDO Accounting, Reporting & Compliance Hub (ARCH) (BDO · Firm guide · Free)
- Deloitte DART – Roadmap Series (Deloitte · Firm guide · Free)
- Grant Thornton Insights (Grant Thornton · Firm guide · Free)
- KPMG Financial Reporting View (KPMG · Firm guide · Free)
- PwC Viewpoint (PwC · Firm guide · Free / paid)
- RSM Financial Reporting Resource Center (RSM · Firm guide · Free)
- SEC – Corporation Finance Interpretations (SEC · Regulator · Free)
- SEC – Financial Reporting Manual (SEC · Regulator · Free)
- The Monday Filer – SEC reporting Excel templates (The Monday Filer · Template vendor · Paid)
- UnfoldCFO – 10-K Disclosure Checklist (UnfoldCFO · Template vendor · See site)
- Workiva Marketplace – SEC Reporting Process Checklist (Workiva · Template vendor · Requires Workiva license)