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SEC Comment Letter for EVERGY METRO, INC. (CIK 0000054476) — Jul 22, 2022

EVERGY METRO, INC. (CIK 0000054476)
Date: July 22, 2022 · CIK: 0000054476 · Accession: 0000000000-22-007717

AI Filing Summary & Sentiment

File numbers found in text: 001-38515

Date
July 22, 2022
Author
Not clearly detected
Form
UPLOAD
Company
EVERGY METRO, INC. (CIK 0000054476)

Letter

United States securities and exchange commission logo July 22, 2022 Kirkland B. Andrews Chief Financial Officer Evergy, Inc. 1200 Main Street Kansas City, Missouri 64105 Re:Evergy, Inc. Form 10-K for the Fiscal Year ended December 31, 2021 Filed February 25, 2022 File No. 001-38515 Dear Mr. Andrews: 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, 2021 Management's Discussion and Analysis of Financial Condition and Results of Operations Executive Summary Non-GAAP Measures, page 38 1.We note that you identify several non-GAAP measures in your Executive Summary though do not mention Utility Gross Margin, which you also identify as a non-GAAP measure for Evergy Inc., Evergy Kansas Central, Inc., and Evergy Metro, Inc. in your tabulations of operating results on pages 45, 55,and 58. We see that you define the measure on page 44 as operating revenues less fuel and purchased power costs and amounts billed by the SPP for network transmission costs.

We also see that you utilize these non-GAAP measures within MD&A in your analyses of operating results. Based on your disclosures, these measures appear to exclude amounts that would be attributable to a GAAP measure of cost of revenue, as would be reflected in

FirstName LastNameKirkland B. Andrews Comapany NameEvergy, Inc. July 22, 2022 Page 2 FirstName LastName Kirkland B. Andrews Evergy, Inc. July 22, 2022 Page 2 a GAAP measure of gross margin. We believe that you should identify gross margin as the most comparable GAAP measure in providing the disclosures required by Item 10(e)(1)(i)(A) and Item 10(e)(1)(i)(B) of Regulation S-K.

Please revise your Executive Summary to include disclosures that encompass these non- GAAP measures along with the most directly comparable GAAP-based measures. Please submit the revisions that you propose to address these prominence and reconciliation requirements, utilizing gross margin as the most comparable GAAP measure. 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 Lily Dang at (202) 551-3867 or Mark Wojciechowski at (202) 551- 3759 if you have questions regarding comments on the financial statements and related matters. Please contact Karl Hiller - Branch Chief at (202) 551-3686 with any other questions. Sincerely, Division of Corporation Finance Office of Energy & Transportation

Show Raw Text
United States securities and exchange commission logo
July 22, 2022
Kirkland B. Andrews
Chief Financial Officer
Evergy, Inc.
1200 Main Street
Kansas City, Missouri 64105
Re:Evergy, Inc.
Form 10-K for the Fiscal Year ended December 31, 2021
Filed February 25, 2022
File No. 001-38515
Dear Mr. Andrews:
            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, 2021
Management's Discussion and Analysis of Financial Condition and Results of Operations
Executive Summary
Non-GAAP Measures, page 38
1.We note that you identify several non-GAAP measures in your Executive Summary
though do not mention Utility Gross Margin, which you also identify as a non-GAAP
measure for Evergy Inc., Evergy Kansas Central, Inc., and Evergy Metro, Inc. in your
tabulations of operating results on pages 45, 55,and 58. We see that you define the
measure on page 44 as operating revenues less fuel and purchased power costs and
amounts billed by the SPP for network transmission costs.

We also see that you utilize these non-GAAP measures within MD&A in your analyses of
operating results. Based on your disclosures, these measures appear to exclude amounts
that would be attributable to a GAAP measure of cost of revenue, as would be reflected in

 FirstName LastNameKirkland B. Andrews
 Comapany NameEvergy, Inc.
 July 22, 2022 Page 2
 FirstName LastName
Kirkland B. Andrews
Evergy, Inc.
July 22, 2022
Page 2
a GAAP measure of gross margin. We believe that you should identify gross margin as
the most comparable GAAP measure in providing the disclosures required by Item
10(e)(1)(i)(A) and Item 10(e)(1)(i)(B) of Regulation S-K.

Please revise your Executive Summary to include disclosures that encompass these non-
GAAP measures along with the most directly comparable GAAP-based measures. Please
submit the revisions that you propose to address these prominence and reconciliation
requirements, utilizing gross margin as the most comparable GAAP measure.
            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 Lily Dang at (202) 551-3867 or Mark Wojciechowski at (202) 551-
3759 if you have questions regarding comments on the financial statements and related
matters.  Please contact Karl Hiller - Branch Chief at (202) 551-3686 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Energy & Transportation