SRSEC Reporting Desk

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

What to check in your filing: Confirm reserve/resource disclosures meet S-K 1200/1300 including QP reports and assumptions.

4 staff comments from 2 companies. Outcomes: Awaiting / response not in dataset: 1, Agreed to revise: 1, Explained / pushed back: 1, Responded: 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 →
Oil, Gas & Mining (S-K 1200/1300)Exhibits, Certifications & Signatures
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 →
Oil, Gas & Mining (S-K 1200/1300)
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 →
Oil, Gas & Mining (S-K 1200/1300)
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 →
Oil, Gas & Mining (S-K 1200/1300)Exhibits, Certifications & Signatures
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