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United States securities and exchange commission logo
December 14, 2023
Brian Willey
EVP and Chief Financial Officer
Matador Resources Company
5400 LBJ Freeway, Suite 1500
Dallas, Texas 75240
Re: Matador Resources
Company
Form 10-K for the
Fiscal Year Ended December 31, 2022
Filed March 1, 2023
File No. 001-35410
Dear Brian Willey:
We have limited our review of your filing to the financial
statements and related
disclosures and have the following comments.
Please respond to this letter 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 a
comment applies to your facts and circumstances, please tell us why in
your response.
After reviewing your
response to this letter, we may have additional comments.
Form 10-K for the Fiscal Year Ended December 31, 2022
Business
Estimated Proved Reserves, page 17
1. We note the
reconciliation of the changes in proved undeveloped reserves includes a line
item entry of 46.4
MMBoe for Extensions and Discoveries that combines additions of
53.8 MMBoe in new
reserves with an offset to remove 7.4 MMBoe for reserves that were
not developed or were
no longer expected to be developed within five years of their initial
bookings as a result of
changes in development plans. We also note you include similar
adjustments to the net
quantities shown in the reconciliation of the changes in total proved
reserves for
Extensions and Discoveries on page F-40 for the years ending December
31, 2022 and 2021,
respectively.
We believe that changes
associated with reclassifying reserves due to changes in a
previously adopted
development plan should be categorized as revisions and included in
the reconciliation
under line item Revisions of Prior Estimates. Refer to the guidance in
Brian Willey
Matador Resources Company
December 14, 2023
Page 2
subparagraphs (a) and (d) of FASB ASC 932-235-50-5 and revise the
classifications
within your proved undeveloped and total proved reserves
reconciliations and the
associated narratives accordingly.
Drilling Results, page 22
2. Please expand or modify the disclosure of your drilling activities to
clarify the extent, if
true, that your exploratory wells include and/or exclusively represent
extension wells.
Refer to the definition of a productive well in Item 1205(b)(2) of
Regulation S-K and the
definitions of an exploratory well and an extension well in Rule
4-10(a)(13) and (a)(14) of
Regulation S-X, respectively. Also, expand your Glossary of Oil and
Natural Gas Terms
to include the definition for an extension well.
Unaudited Supplementary Information
Supplemental Oil and Natural Gas Disclosures
Standardized Measure of Discounted Future Net Cash Flows and Changes Therein
Relating to
Proved Oil and Gas Reserves, page F-42
3. We note disclosure in footnote (4) on page 18 clarifies the
standardized measure includes
future plugging and abandonment expenses. Please expand the discussion
accompanying
the presentation of the standardized measure on page F-42 to include a
similar statement.
Refer to FASB ASC 932-235-50-36.
In closing, 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.
Please contact John Hodgin, Petroleum Engineer, at (202) 551-3699 with
any questions
regarding the comments. Please contact Craig Arakawa, Branch Chief, at (202)
551-3650 with
any other questions.
FirstName LastNameBrian Willey Sincerely,
Comapany NameMatador Resources Company
Division of
Corporation Finance
December 14, 2023 Page 2 Office of Energy
& Transportation
FirstName LastName