United States securities and exchange commission logo
May 2, 2024
Marcelo Cunha Ribeiro
Chief Financial Officer
National Steel Company
Av.Brigadeiro Faria Lima, 3400 - 20th floor
Sao Paulo-SP, Brazil 04538-132
Re: National Steel
Company
Form 20-F for the
Year Ended December 31, 2022
Response dated
April 2, 2024
File No. 001-14732
Dear Marcelo Cunha Ribeiro:
We have reviewed your April 2, 2024 response to our comment
letter 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. Unless
we note otherwise, any references to prior comments are to comments in
our March 19,
2024 letter.
Form 20-F/A filed April 26, 2024
Item 4. Information on the Company, page 1
1. Please provide an
updated reconciliation with depletion due to mining activities for your
resources/reserves as
reported in the most recent year compared to the prior year, as
required by Item
1304(e) of Regulation S-K and confirm that you will include this
reconciliation in
subsequent annual filings. Note that this is only required for material
properties.
2. Please provide proposed
disclosure of non-material resource and reserve tables which
includes the following,
as required by Item 1303(b)(3) of Regulation S-K:
the point of
reference in which reserves and resources are calculated, such as in-situ,
mill feed,
saleable product, etc; and
the currency with
respect to the pit optimization parameters on page 26.
Marcelo Cunha Ribeiro
National Steel Company
May 2, 2024
Page 2
If you have any questions regarding mining comments, please contact John
Coleman
at 202-551-3610 or Craig Arakawa at 202-551-3650. Please contact Melissa
Gilmore at 202-551-
3777 or Kevin Woody at 202-551-3629 if you have any other questions.
FirstName LastNameMarcelo Cunha Ribeiro Sincerely,
Comapany NameNational Steel Company
Division of Corporation
Finance
May 2, 2024 Page 2 Office of Manufacturing
FirstName LastName