March 16, 2017
VIA EMAIL
United States
Securities and Exchange Commission
Washington, D.C. 201549
Attention:
Craig Arakawa, Accounting Branch Chief
Office of Beverages, Apparel and Mining
Dear Sirs:
Re:
Rise Resources, Inc.
Form 10-K for the Fiscal Year Ended July 31, 2016
Filed October 31, 2016
Form 10-Q for the Quarterly Period Ended October 31, 2016
Filed on December 9, 2016
File No. 000-53848
We write in response to your letter of February 28, 2017. We provide the following responses to your comments:
Form 10-K for the Fiscal Year Ended July 31, 2016
Item 1. Business Description of Business
1.
We have deleted reference to “indicated resource” on page 23 and “inferred resource” on page 28.
2.
We have added a new section “Data Verification and Quality Assurance” to page 30.
Item 9A. Controls and Procedures
3.
We have provided a conclusion regarding the effectiveness of our disclosure controls and procedures and provided management’s annual report on internal control over financial reporting.
Form 10-Q for the Quarterly Period Ended October 31, 2016
Item 4. Controls and Procedures
4.
We have provided a conclusion regarding the effectiveness of our disclosure controls and procedures.
Yours truly,
Rise Resources Inc.
Per: | /s/ Cale Thomas |
| Cale Thomas, Chief Financial Officer |
Suite 488, 1090 West Georgia Street, Vancouver, BC V6E 3V7
(604) 260-4577 risecapitalresources.com