United States securities and exchange commission logo
August 31, 2022
Christopher M. Abundis
EVP, CFO, General Counsel & Secretary
SILVERBOW RESOURCES, INC.
920 Memorial City Way, Suite 850
Houston, Texas 77024
Re: SILVERBOW
RESOURCES, INC.
Form 10-K for the
Fiscal Year Ended December 31, 2021
Filed March 3, 2022
File No. 001-08754
Dear Mr. Abundis:
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 for the Fiscal Year Ended December 31, 2021
Business and Properties
Oil and Natural Gas Reserves, page 9
1. Please expand your
disclosure to provide a general discussion of the technologies used to
establish the
appropriate level of certainty for material additions to your proved reserves
estimates. Refer to
Item 1202(a)(6) of Regulation S-K.
Proved Undeveloped Reserves, page 12
2. We note your disclosure
of a tabular summary that sets forth the net volumes of proved
undeveloped reserves
and the year these reserves were added. Please expand your
disclosure to clarify
that all of the proved undeveloped reserves disclosed as of December
31, 2021 are part of a
development plan and drilling schedule adopted by your
management resulting in
the conversion of these reserves within five years of initial
disclosure. Refer to
Rule 4-10(a)(31)(ii) of Regulation S-X and Question 131.04 in our
Christopher M. Abundis
FirstName LastNameChristopher M. Abundis
SILVERBOW RESOURCES, INC.
Comapany
August 31, NameSILVERBOW
2022 RESOURCES, INC.
August
Page 2 31, 2022 Page 2
FirstName LastName
Compliance and Disclosure Interpretations (C&DIs) regarding Oil and
Gas Rules.
3. If there are material amounts of proved undeveloped reserves as of
December 31, 2021
that will not be converted to proved developed status within five
years of initial disclosure
as proved reserves, please expand your disclosure to explain the
reasons for the delay.
Refer to Item 1203(d) of Regulation S-K and Question 131.03 in the
Compliance and
Disclosure Interpretations (C&DIs).
Oil and Gas Wells, page 13
4. Please expand your disclosure of the gross and net oil and gas wells
in which the
Company owned interests to clarify, if true, that these wells are
productive wells pursuant
to the disclosure requirement in Item 1208(a) and definition of a
productive well in
1208(c)(3) of Regulation S-K.
This comment also applies to your disclosure of producing wells
shown in the table of
results of the Company s drilling and completion activities on page
14. Refer to the
disclosure requirements in Item 1205(a) and the definitions in part
(b) of Regulation S-K,
which clarifies the number of wells drilled refers to the number of
wells completed at any
time during the year, regardless of when drilling was initiated.
To the extent that the wells shown in your tabular summaries do not
comply with these
requirements, please revise your disclosure accordingly.
Supplemental Information (Unaudited)
Supplemental Reserves Information, page 80
5. Please expand the tabular presentation of your proved developed and
proved undeveloped
reserves, by individual product type, to additionally provide the net
quantities at the
beginning of each year shown in the reconciliation, e.g. December 31,
2019. Refer to the
disclosure requirements pursuant to FASB ASC 932-235-50-4.
6. We note you identify the reclassification of PUDs to unproved due to
changes in the
Company s five-year development plan as the single primary factor
that contributed to the
revisions in the previous estimates of your total proved reserves for
the years ending
December 31, 2021 and 2020. Please modify your discussion to identify
all of the factors
that contributed to the overall change in the line item. If two or
more unrelated factors,
including offsetting factors, are combined to arrive at the overall
change, please separately
identify and quantify each factor.
For example, the disclosure pertaining to revisions in previous
estimates of your reserves
should identify the changes associated with individual factors, such
as changes in
commodity prices, costs, property interests, well performance,
unsuccessful and/or
uneconomic proved undeveloped locations, and previously adopted
development plans.
Your discussion should provide sufficient details so that the change
in net reserve
quantities between periods is fully reconciled and explained to comply
with FASB ASC
Christopher M. Abundis
SILVERBOW RESOURCES, INC.
August 31, 2022
Page 3
932-235-50-5.
This comment also applies to the disclosure of the changes in proved
undeveloped
reserves presented on page 12. Refer to Item 1203(b) of Regulation S-K.
7. We also note the change in total proved reserves attributed to extensions
and
discoveries of 359.4 Bcfe, for the year ended December 31, 2021, appears
to be
significantly greater than the corresponding change in proved undeveloped
reserves of
313.2 Bcfe.
Please expand the discussion of the changes in your total proved reserves
attributed to
extensions and discoveries to explain the reason(s) for this difference.
Refer to FASB
ASC 932-235-50-5.
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 Sandra Wall, Petroleum Engineer, at (202) 551-4727 or
John Hodgin,
Petroleum Engineer, at (202) 551-3699 if you have questions regarding the
engineering
comments. Please contact Steve Lo, Staff Accountant, at (202) 551-3394 or Raj
Rajan, Staff
Accountant, at (202) 551-3388 with any other questions.
Sincerely,
FirstName LastNameChristopher M. Abundis
Division of
Corporation Finance
Comapany NameSILVERBOW RESOURCES, INC.
Office of Energy &
Transportation
August 31, 2022 Page 3
cc: Annie Foley
FirstName LastName