SecProbe.io

March 6, 2020
Fabian Souza
Senior Vice President and Corporate Controller
EXELON CORP
10 South Dearborn Street
P.O. Box 805379
Chicago, Illinois 60680-5379
Re:EXELON CORP
Form 10-K for the Fiscal Year Ended December 31, 2019
Filed February 11, 2020
File No. 001-16169
Dear Mr. Souza:
            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 the Fiscal Year Ended December 31, 2019
Item 7. Management’s Discussion and Analysis of Financial Condition and Results of
Operations
FERC Order on the PJM MOPR, page 66
1.You disclose that if Generation’s state-supported nuclear plants in PJM or NYISO are
subjected to the Minimum Offer Price Rule (MOPR) without compensation under an
Fixed Resource Requirement (FRR) or similar program, it could have a material adverse
impact on Exelon's and Generation's financial statements.  In this regard, please tell us
what consideration you gave to quantifying the expected impact of this known uncertainty
on your future results of operations.  Refer to Item 303(a)(3)(ii) of Regulation S-K.

 FirstName LastNameFabian Souza
 Comapany NameEXELON CORP
 March 6, 2020 Page 2
 FirstName LastNameFabian Souza
EXELON CORP
March 6, 2020
Page 2

Critical Accounting Policies
Depreciable Lives of Property, Plant and Equipment (All Registrants), page 78
2.We note from your disclosure on page 267 that you recorded significant charges to
earnings associated with accelerated depreciation due to early nuclear plant retirements
over the last three fiscal years.  We also note your disclosure in footnote 6 regarding the
economic challenges faced by your nuclear generating stations and the resulting potential
for early retirement of the Dresden, Byron, and Braidwood nuclear plants in Illinois.  We
also note that you have recorded charges to earnings over the last three fiscal years
associated with early nuclear plant retirements.  Please tell us your consideration of
providing additional disclosures in your critical accounting policies that allows for an
assessment of the probability, magnitude and timing of future material charges associated
with accelerated deprecation or early retirement or shutdown of the Dresden, Byron and
Braidwood units, the net book value and revenues of the business units along with a
description of the specific events and/or changes in circumstances that could reasonably
be expected to result in accelerated deprecation or early retirement or shutdown.  Lastly,
please address how the early retirement of these units would necessitate any incremental
charges associated with their asset retirement obligations.   Refer to Section V of SEC
Release 33-8350 and Item 303(a)(3)(ii), which requires a description of a known
uncertainty that will have a material impact on income from continuing operations.
Results of Operations by Registrant, page 84
3.We note your presentation of the non-GAAP measure revenues net of purchased power
and fuel expense.  Please present a reconciliation for this non-GAAP measure in
accordance with Item 10(e)(1)(i)(B) of Regulation S-K.  In doing so, reconcile this
measures to the most directly comparable GAAP measure of gross margin.  If you do not
believe gross margin that includes depreciation and amortization is the most directly
comparable GAAP measure, please tell us why in your response.
Item 8. Financial Statements and Supplementary Data
Note 18 — Commitments and Contingencies
Asbestos Personal Injury Claims (Exelon and Generation), page 346
4.We note your disclosure that it is reasonably possible that additional exposure to estimated
future asbestos-related bodily injury claims in excess of the amount accrued could have a
material, unfavorable impact on Exelon’s and Generation’s financial statements.  If it is at
least reasonably possible that a loss exceeding amounts already recognized may have been
incurred and the amount of that additional loss would be material, either disclose the
estimated additional loss, or range of loss that is reasonably possible, or state that such an
estimate cannot be made.  Refer to ASC 450-20-50-4.

 FirstName LastNameFabian Souza
 Comapany NameEXELON CORP
 March 6, 2020 Page 3
 FirstName LastName
Fabian Souza
EXELON CORP
March 6, 2020
Page 3
            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 Robert Babula, Staff Accountant at (202) 551-3339, or Gus Rodriguez,
Branch Chief at (202) 551-3752 if you have questions regarding comments on the financial
statements and related matters.
Sincerely,
Division of Corporation Finance
Office of Energy & Transportation