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United States securities and exchange commission logo
September 10, 2021
David Lancaster
Chief Financial Officer
Matador Resources Company
5400 LBJ Freeway, Suite 1500
Dallas, Texas 75240
Re: Matador Resources
Company
Form 10-K for
Fiscal Year Ended December 31, 2020
Filed February 26,
2021
File No. 001-35410
Dear Mr. Lancaster:
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 Fiscal Year Ended December 31, 2020
Business
Estimated Proved Reserves, page 17
1. Your explanation of the
changes in proved undeveloped reserves related to revisions of
prior estimates appears
to include changes from two or more unrelated factors as well as
both positive and
negative changes summed into a single quantity without further
explanation. For
example, the revisions for 2020 identified the removal of certain
undeveloped reserves as
a result of lower weighted average oil and natural gas prices;
however, the proved
undeveloped reserves revisions of prior estimates shown is positive.
Revise your disclosure
to address the overall change by separately identifying and
quantifying the net
amount attributable to each contributing factor, including offsetting
factors, so the change
in proved undeveloped reserves due to revisions of prior estimates
is fully explained.
Refer to the disclosure requirements in Item 1203(b) of Regulation S-K.
David Lancaster
FirstName LastNameDavid Lancaster
Matador Resources Company
Comapany 10,
September NameMatador
2021 Resources Company
September
Page 2 10, 2021 Page 2
FirstName LastName
Drilling Results, page 22
2. Expand your disclosure to address your present activities, including
the number of gross
and net wells in the process of being drilled, completed, or waiting
on completion, and
other related activities of material importance as of December 31,
2020. Refer to the
disclosure requirements in Item 1206 of Regulation S-K
Undeveloped Acreage Expiration, page 22
3. We note that approximately 39%, 25% and 13% of your total net
undeveloped acres will
expire over the next three years, respectively. Expand your disclosure
to clarify the extent
that you have any proved undeveloped locations currently scheduled to
be drilled after the
expiration date of the lease. If there are material quantities of
proved undeveloped
reserves attributable to these locations, also disclose the costs
which would be necessary
to extend the time to the expiration of your acreage. Refer to Rule
4-10(a)(26) of
Regulation S-X and FASB ASC 932-235-50-10.
Unaudited Supplementary Information
Supplemental Oil and Natural Gas Disclosures, page F-38
4. Your explanation of the changes in total proved reserves related to
revisions of prior
estimates appears to include changes from two or more unrelated
factors as well as both
positive and negative changes summed into a single quantity without
further details. For
example, your 2020 revision of prior estimates identified
better-than-projected well
performance from certain wells which were offset by downward revisions
attributable to
lower weighted average oil and natural gas prices. Revise your
disclosure to identify and
quantify the net amount, if significant, relating to each contributing
factor separately,
including offsetting factors so the change due to revisions of prior
estimates is fully
explained. Refer to the disclosure requirements in FASB ASC
932-235-50-5.
5. Your disclosure of changes to total proved reserves attributed to
extensions and
discoveries on pages 18 and F-40 appears to be significantly greater
than the
corresponding change in the net quantities of proved undeveloped
reserves disclosed on
page 20 for the year ended 2020. For example, the change in total
proved reserves for the
year ended December 31, 2020 is 35.3 MMBoe compared to the change in
proved
undeveloped reserves of 20.1 MMBoe. We note similar differences in the
estimates for the
years ended December 31, 2019 and 2018, respectively. Expand the
discussion of the
changes in your total proved reserves attributable to extensions and
discoveries for each
period presented to include the reason(s) for this difference. Refer
to the disclosure
requirements in FASB 932-235-50-5.
Standardized Measure of Discounted Future Net Cash Flows and Changes Therein
Relating to
Proved Oil and Natural Gas Reserves, page F-41
6. The reserve report, filed as Exhibit 99.1, indicates that the
estimates of future net revenue
David Lancaster
Matador Resources Company
September 10, 2021
Page 3
do not include any salvage value for the lease and well equipment or
the cost of
abandoning the properties. However, disclosure provided in footnote
(4) on page 18
appears to indicate that estimates of the standardized measure
presented in Form 10-K for
the year ended December 31, 2020 represent the present value of
estimated future net cash
flows less the estimated costs for plugging and abandonment. Please
resolve for us this
apparent inconsistency in disclosure relating to the costs included in
your calculation of
the standardized measure.
7. If the abandonment costs, including the costs related to your proved
undeveloped
locations, have not been included in your calculation of the
standardized measure, please
tell us the undiscounted dollar amounts and the dollar amounts
discounted at ten percent
for each of the periods presented, e.g. as of December 31, 2020, 2019
and 2018,
respectively, and explain to us your rationale for excluding these
costs from your
calculation of the standardized measure.
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 if
you have
questions regarding the engineering comments. Please contact Ethan Horowitz,
Branch Chief, at
(202) 551-3311 with any other questions.
FirstName LastNameDavid Lancaster Sincerely,
Comapany NameMatador Resources Company
Division of
Corporation Finance
September 10, 2021 Page 3 Office of Energy
& Transportation
FirstName LastName