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July 20, 2022
Jason Wells
Chief Financial Officer
CenterPoint Energy, Inc.
1111 Louisiana St.
Houston, TX 77002
Re:CenterPoint Energy, Inc.
Form 10-K for the Fiscal Year ended December 31, 2021
Filed February 22, 2022
File No. 001-31447
Dear Mr. Wells:
            We have limited our review of your filing to the financial statements and related
disclosures 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, 2021
Management's Discussion and Analysis of Financial Condition and Results of Operations
CenterPoint Energy Consolidated Results of Operations, page 45
1.We note that you describe, though without quantification, various key factors that are
associated with the change in net income or loss attributable to common shareholders, as
well as key factors that are associated with the change in unspecified non-GAAP
measures, arising from your exclusion of effects attributed to other key factors, in
comparing the various periods. We see that you have taken a similar approach in your
interim report for the fiscal quarter ended March 31, 2022.

We believe that you will need to revise your disclosures in the annual and interim reports
to quantify the impact of each key factor described in these comparisons, consistent with
the requirements of Item 303(a), (b), (b)(2)(i), and (c) of Regulation S-K; the magnitude

 FirstName LastNameJason Wells
 Comapany NameCenterPoint Energy, Inc.
 July 20, 2022 Page 2
 FirstName LastNameJason Wells
CenterPoint Energy, Inc.
July 20, 2022
Page 2
and relative contribution of each key factor on the overall change in net income or loss
attributable to common shareholders should be clear. Please submit the revisions that you
propose to address these concerns in amendments to your annual and interim reports.
2.We note that you disclose, along with your descriptions of key factors that
impacted income or loss attributed to common shareholders, quantification of the overall
change on an adjusted basis, i.e. excluding amounts associated with "those items" though
without specification or quantification of the particular items or of the adjusted amounts.

For example, near the end of page 45, you explain that income available to common
shareholders increased $191 million in 2021, excluding those items, and following the
first three points on page 46, you explain that income available to common shareholders in
2020 increased $115 million, excluding those items. We see that you have taken a similar
approach in your interim report for the fiscal quarter ended March 31, 2022.

We believe that you should quantify the non-GAAP measures that are being utilized in
your discussion and analysis, and provide the disclosures that are prescribed by Item 10(e)
of Regulation S-K, including equally prominent disclosure of and reconciliation from the
most comparable GAAP based measure. Please submit the revisions that you propose to
address these concerns in amendments to your annual and interim reports.
CenterPoint Energy's Results of Operations by Reportable Segment, page 46
3.We note that you present measures described as revenues less cost of revenues in your
tabulations on pages 47, 49 and 53, and reference these amounts in your variance
explanations on pages 48, 50, and 54, covering your results of operations for the segments
and CERC.  We see that you have taken a similar approach in your interim report for the
fiscal quarter ended March 31, 2022.

However, these measures appear to be incomplete, due to the exclusion of depreciation
and amortization and certain operation and maintenance costs that would be attributable to
cost of revenues under GAAP. If your cost of revenues measures are incomplete, the
margin measures should be identified as non-GAAP measures, and you should provide
the disclosures prescribe by Item 10(e) of Regulation S-K, including equally prominent
disclosure of, and a reconciliation from, the most comparable GAAP based measure,
which we believe would be a GAAP measure of gross profit or margin.

Alternatively, if you did not intend to present non-GAAP margin measures you may
correct your compilation of cost of revenues and the margin measures to conform with
GAAP. Please submit the revisions that you propose to address these concerns in
amendments to your annual and interim reports.

 FirstName LastNameJason Wells
 Comapany NameCenterPoint Energy, Inc.
 July 20, 2022 Page 3
 FirstName LastName
Jason Wells
CenterPoint Energy, Inc.
July 20, 2022
Page 3
Financial Statements
Note 16 - Commitments and Contingencies
Litigation Related to the February 2021 Winter Storm Event, page 164
4.We note your disclosure explaining that you or your subsidiaries have received claims and
lawsuits filed by plaintiffs alleging personal injury, property damage and other injuries
and damages associated with the Winter Storm Event, and have become involved in
various investigations, litigation and regulatory and legal proceedings regarding efforts to
restore power and compliance with NERC, ERCOT and PUCT rules and directives.

You further clarify that you or your subsidiaries are named as defendants in litigation
arising from this event, including claims for wrongful death, personal injury, property
damage, impacts on businesses, shareholders and other matters.  You indicate that you are
unable to estimate a range of potential losses, although you have not quantified any
damages sought by the counterparties in the matters referenced by this disclosure, or the
corresponding disclosure on page 40 of your recent interim report.

Given that you are unable to estimate the possible loss or range of loss, we understand that
you are unable to conclude that your exposure to loss would not encompass the amounts
of damages claimed.  Therefore, you should disclose any quantification of damages
sought by the counterparties in the litigation referenced by this disclosure to comply with
FASB ASC 450-20-50-3.  Please revise your disclosure to include such information or to
clarify if there has been no such quantification by the litigants.

Also revise your disclosure on page 42, stating that "CenterPoint Energy does not, at this
time, anticipate long-term financial impacts associated with the February 2021 Winter
Storm Event," to clarify if your expectations are for near-term settlement of
litigation rather than a more distant timeframe, where the impacts could nevertheless be
material, or to clarify if you have assessed your exposure to material loss as remote.
            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.  You may contact Jenifer Gallagher, Staff Accountant at (202)
551-3706 or Karl Hiller, Branch Chief at (202) 551-3686 with any questions.
Sincerely,
Division of Corporation Finance
Office of Energy & Transportation