SRSEC Reporting Desk

Coeur Mining, Inc. (CDE) – SEC staff letter

2025-12-12 · Re: Form 10-Q for the Fiscal Quarter Ended September 30, 2025 Form 10-K for the Fiscal Year Ended December 31, 2024 Response dated September 3, 2025 · Accession 0000000000-25-011533 · 1 staff comment(s) issued

Company response(s): 2025-12-22

Non-GAAP: Adjustments & LabelsNon-GAAP: Reconciliation & Usefulness

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 →
Non-GAAP: Adjustments & LabelsNon-GAAP: Reconciliation & Usefulness

Full letter on EDGAR → · Filing index · All Coeur Mining, Inc. (CDE) correspondence

Non-GAAP: Adjustments & Labels – what to check: Do not exclude normal, recurring cash operating expenses or use individually tailored recognition methods; label measures clearly (C&DI 100.01–100.04).

Non-GAAP: Reconciliation & Usefulness – what to check: Reconcile every non-GAAP measure (including segment-level measures presented outside the ASC 280 note) to the most directly comparable GAAP measure, and explain why it is useful.

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