United States securities and exchange commission logo
December 16, 2022
Julie Z. Weedman
Senior Vice President and CFO
Golden Minerals Company
350 Indiana Street, Suite 650
Golden, Colorado 80401
Re: Golden Minerals
Company
Form 10-K for the
fiscal year ended December 31, 2021
Filed March 23,
2022
File No. 001-13627
Dear Julie Z. Weedman:
We have reviewed your filing and have the following comments. In
some of our
comments, we may ask you to provide us with information so we may better
understand your
disclosure.
Please respond to these comments within ten business days by
providing the requested
information or advise us as soon as possible when you will respond. If
you do not believe our
comments apply to your facts and circumstances, please tell us why in
your response.
After reviewing your
response to these comments, we may have additional comments.
Form 10-K
Rodeo Property, page 17
1. The longitude listed
for your Rodeo property appears to be 104 degrees W. Please review
and modify both your
filing and technical report. See Item 1304(b)(2)(i) of Regulation S-
K. Please note the
coordinates listed for the El Quevar property also appear to be in error.
Title and Ownership Rights, page 19
2. Please modify your
filing to include the book value of your property in this section and
elsewhere as required
by Item 1304(b)(1)(iii) of Regulation S-K.
Mineral Resources Estimate, page 21
3. Please modify your
filing to provide an explanation for your lack of a reconciliation of
your resources over the
last two years. See Item 1304(e) of Regulation S-K.
Julie Z. Weedman
Golden Minerals Company
December 16, 2022
Page 2
Exhibit 96.1 - Rodeo
Property Description and Ownership, page 1 & 7, page ES-1
4. The longitude listed for your Rodeo property appears to be 104 degrees
W. Please review
and modify your technical report. See Item 601(b)(96)(iii)(B)(3)(i) of
Regulation S-K.
Exhibit 96.1 - Rodeo
Resources, page 34, page ES-34
5. Please modify your technical report to include your Qualified persons
opinion on issues
affecting the prospect of economic extraction as required by Item
601(b)(96)(iii)(B)(11)(vii) of Regulation S-K.
Exhibit 96.1 - Rodeo
Mining Methods, page 36, page ES-36
6. Please modify your technical report to provide the annual Life of Mine
(LOM) production
with associated grades as required by Item 601(b)(96)(iii)(B)(13) of
Regulation S-K.
Exhibit 96.1 - Rodeo
Market Studies, page 43, page ES-43
7. We note your commodity price forecast in the section. Please modify
your technical
report to describe, list, and provide the dates your bank forecast
projections were
performed as required by Item 601(b)(96)(iii)(B)(16) of Regulation
S-K.
Exhibit 96.1 - Rodeo
Economic Analysis, page 49, page ES-49
8. Please modify your technical report to include the annual processed
tonnage and grade
along with the salable gold/silver ounces in your cash flow analysis.
In addition please
include all taxes and present your analysis on an after tax basis as
required by Item
601(b)(96)(iii)(B)(19) of Regulation S-K.
Exhibit 96.2 - Velardena
Mineral Processing
FirstName and Metallurgical
LastNameJulie Z. Weedman Testing, Page 31, page ET-31
Comapany
9. NameGolden
Please modify yourMinerals
filing toCompany
provide your estimate of your metallurgical
recovery. See
Item 601(b)(96)(iii)(B)(10)(iv)
December 16, 2022 Page 2 of Regulation S-K.
FirstName LastName
Julie Z. Weedman
FirstName LastNameJulie
Golden Minerals CompanyZ. Weedman
Comapany16,
December NameGolden
2022 Minerals Company
December
Page 3 16, 2022 Page 3
FirstName LastName
Exhibit 96.2 - Velardena
Mineral Resource Estimates, page 35, page ET-35
10. Please modify your technical report to describe how your Net Smelter
return (NSR) is
calculated, and provide the cost parameters for this calculation. In
addition, please
provide the smelter terms and conditions. See Item
601(b)(96)(iii)(B)(11)(iii) of
Regulation S-K.
Exhibit 96.2 - Velardena
Mining Methods, Page 38, page ET-38
11. Please modify your technical report to provide the annual Life of Mine
(LOM) production
with associated grades as required by Item 601(b)(96)(iii)(B)(13) of
Regulation S-K.
Exhibit 96.2 - Velardena
Market Studies, Page 52, page ET-52
12. We note your commodity price forecast in the section. Please modify
your technical
report to describe, list, and provide the dates your bank forecast
projections were
performed as required by Item 601(b)(96)(iii)(B)(16) of Regulation
S-K.
Exhibit 96.2 - Velardena
Economic Analysis, Page 60 & 63, page ET-60
13. Please modify your technical report to include the annual processed
tonnage and grade
along with the salable commodities in your cash flow analysis. In
addition please include
reclamation costs, all taxes and present your analysis on an after tax
basis as required by
Item 601(b)(96)(iii)(B)(19) of Regulation S-K.
We remind you that the company and its management are responsible for
the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action
or absence of
action by the staff.
You may contact George K. Schuler at 202-551-3718 if you have questions
regarding
the engineering comments or Craig Arakawa at at 202-551-3650 with any other
questions.
Sincerely,
Division of
Corporation Finance
Office of Energy
& Transportation