SRSEC Reporting Desk

5E Advanced Materials, Inc. (FEAM, FEAV) – SEC staff letter

2026-02-10 · Re: Form 10-K for the Fiscal Year ended June 30, 2025 Filed September 29, 2025 · Accession 0000000000-26-001381 · 2 staff comment(s) issued

Company response(s): 2026-02-25

Oil, Gas & Mining (S-K 1200/1300)Exhibits, Certifications & Signatures

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 →
Oil, Gas & Mining (S-K 1200/1300)
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 →
Oil, Gas & Mining (S-K 1200/1300)Exhibits, Certifications & Signatures

Full letter on EDGAR → · Filing index · All 5E Advanced Materials, Inc. (FEAM, FEAV) correspondence

Oil, Gas & Mining (S-K 1200/1300) – what to check: Confirm reserve/resource disclosures meet S-K 1200/1300 including QP reports and assumptions.

Exhibits, Certifications & Signatures – what to check:

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