Seward & Kissel llp
ONE BATTERY PARK PLAZA
NEW YORK, NEW YORK 10004
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TELEPHONE: (212) 574-1200
FACSIMILE: (212) 480-8421
WWW.SEWKIS.COM
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901 K STREET, NW
WASHINGTON, D.C. 20001
TELEPHONE: (202) 737-8833
FACSIMILE: (202) 737-5184
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Re:
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Nordic American Tankers Limited
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Form 20-F for the Year Ended December 31, 2015
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Filed March 23, 2016
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File No. 001-13944
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1.
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Refer to your discussion of Vessel Impairment. We note you have omitted tabular disclosure and related discussion previously included in the fiscal year ended December 31, 2015 Annual Report on Form 20-F of the rates used in your undiscounted cash flow analysis, the break even rate and the actual rates achieved for the current year and recent five year period. Please provide for us, and consider including such tabular disclosure and discussion in the December 31, 2016 Form 20-F, to be filed.
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2.
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We note your disclosure of operating cash flow per share. Please remove this measure as it does not comply with the Staff's Compliance and Disclosure Interpretations (C&DIs) Question 102.05 issued by the Division of Corporation Finance on May 17, 2016.
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3.
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We also note that your definition of computation of operating cash flow differs from the typical calculation of cash flows from operating activities presented in the statement of cash flows under U.S. GAAP. Therefore, please revise the title of this non-GAAP measure so it is not confused with cash flows from operating activities.
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Sincerely,
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/s/ Gary J. Wolfe
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Gary J. Wolfe
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cc:
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Claire Erlanger
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Division of Corporation Finance
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Securities and Exchange Commission
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Herbjørn Hansson
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Chairman
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Nordic American Tankers Limited
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