APA Corporation (APA) SEC comment letters

When the SEC's staff reviews a filing, it writes to the company with numbered questions, and the company answers each one in a letter. SEC publishes the exchange once the review is over, at least 20 business days later. Below: what the staff asked APA, and the company's answer to each question, quoted from the letters. A question is not an accusation; most reviews end with the company adding detail to its next filing.

Form 10-K for the fiscal year ended December 31, 2023

2024-07-23 to 2024-08-28 · 1 question · 1 letter from the SEC, 2 from the company

Review closed 2024-08-28

Reserves and insurance

SEC letter of 2024-07-23 ↗ → company's reply of 2024-07-26 ↗

Operating Areas · Other Exploration, page 6

SEC asked

1. You disclose that successful appraisal of two key oil discoveries "confirmed combined recoverable resources of an estimated 700 million barrels of oil for the two fields". Please note that disclosure of quantities other than reserves in an annual report on Form 10-K is generally prohibited. See the instruction to Item 1202 of Regulation S-K and revise your disclosure accordingly.
Rest of the question

Business Overview Upstream Exploration and Production Drilling Statistics, page 7 We note that 7.7 nets wells (10%) of the 73.8 net development wells drilled in Egypt during 2023 were dry; however, during the prior five years (2018 to 2022) only 3 net 2. development wells (1%) of the total 226.7 net development wells drilled in Egypt were dry. Please provide as supplemental information a reasonably detailed explanation for the higher dry hole rate during 2023, including any effect on your future development plans in Egypt. Additionally, tell us the following: • Whether any proved undeveloped reserves were included for the 7.7 net dry wells at year-end 2022, and if so, the quantity of those reserves and where the downward revision is reflected in the 2023 reserve roll-forward; • Whether and how actual drilling results differed from assumptions underlying the decision to drill these wells; • Whether the results on these wells led you to reevaluate reserve estimates for any other wells; and, • Where any downward revisions attributable to any related wells are reflected in the 2023 reserve roll-forward.

APA answered

(“APA”) submits this letter in connection with the comments from the staff of the Securities and Exchange Commission received by letter dated July 23, 2024 (the “Comment Letter”) relating to the above referenced filing of

APA.

APA is working expeditiously to respond to the Comment Letter. APA respectfully requests an extension of time to respond to the inquiries contained in the Comment Letter. APA currently anticipates submitting a response to the Comment Letter on or before August 15, 2024. Read in the reply ↗

In its next report

First report after the company's reply of 2024-07-26: 10-Q filed 2024-08-02 ↗, against the 10-Q filed 2024-05-02 ↗.

Tickdelta does not hold the text of both reports, so they are not compared here.

Also in this review: company letter, 2024-08-15, closing letter, 2024-08-28

From the SEC's correspondence on EDGAR: staff letters (form UPLOAD) and company letters (form CORRESP), 8 letters filed since 2024-02-13. Questions and answers are matched by their numbers; topics come from words in each question. The reports are compared word for word (same form, before the first SEC letter against the first report after the company's reply). No AI.

APAAPA Corporation

Form 10-K for the fiscal year ended December 31, 2023