SEC Comment Letter for Smart Powerr Corp. (CREG) (CIK 0000721693) (CREG) — Jan 30, 2008
Smart Powerr Corp. (CREG) (CIK 0000721693)
Date: Jan. 30, 2008 · CIK: 0000721693 · Accession: 0000000000-08-005163
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 000-12536
Referenced dates: December 14, 2007
Letter
January 15, 2008 Mail Stop 4561 By U.S. Mail and facsimile to (212) 219-3604 Mr. Guangyu Wu, Chief Executive Officer China Recycling Energy Corporation 429 Guangdong Road Shanghai, People’s Republic of China 200001 RE: China Recycling Energy Corporation File No. 000-12536 Form 10-KSB for the year ended December 31, 2006 Forms 10-QSB for the quarters ended March 31, 2007, June 30, 2007 and September 30, 2007
Dear Mr. Wu: We have reviewed your response letter dated December 14, 2007 and have the following comments. Where indicated, we think you should revise your documents in response to these comments. If you disagree, we will consider your explanation as to why our comment is inapplicable or a revision is unnecessary. Pl ease be as detailed as necessary in your explanation. In some of our comments, we may ask you to provide us with additional information so we may better understand your disclosure. After reviewing this information, we may or may not raise additional comments. Please understand that the purpose of our re view process is to assist you in your compliance with the applicable disclosure requirements and to enhance the overall disclosure in your filing. We look forward to working with you in these respects. We welcome any questions you may have about our comment or on any other aspect of our review. Feel free to call us at the tele phone numbers listed at th e end of th is letter.
China Recycling Energy Corporation Page 2 of 3 Form 10-KSB
Financial Statements
Note 4 – Impairment Write Down Recognized As A Result Of Strategic Review of Certain Operations, page 9 1. We have read and considered your respons e to comment three. Please revise your statement of operations to reflect the im pairment loss on property and equipment and deposit for business acquisition as a charge to earnings in accordance with paragraph 25 of SFAS 144. Also, please not e that paragraph 15 of SFAS 5, which was cited in support for your accounting tr eatment, prohibits charging costs or losses to an appropriation of retained earnings. Forms 10-QSB for the quarters ended March 31, 2007, June 30, 2007 and September 30, Financial Statements
Condensed Consolidated Balance Sheet
2. We have read and considered your re sponse to comment six relating to the amount reported as “Due from a third pa rty.” We noted this amount is trade related, due from a single debtor, unsecu red and it relates to the mobile phone distribution business that you discon tinued in May 2007. Also, it appears it remained uncollected as of September 30, 2007. Please explain to us how you determined that the collection of this receivable was reasonably assured and accordingly, no allowance was necessary as of September 30, 2007. 3. Also, explain to us how you evaluated th e risks due to this substantial asset concentration, and how you considered provi ding audited financial statements of the debtor for an investor’s financial assessment of the Company.
As appropriate, please amend your filings and respond to these comments within 10 business days or tell us when you will provid e us with a response. You may wish to provide us with marked copies of the amendm ent to expedite our review. Please furnish a cover letter with your amendment that keys your responses to our comments and provides any requested information. Detailed response letters great ly facilitate our review. Please submit your cover letter on EDGAR. Please understand that we may have additional comments after reviewing your amendment and responses to our comments.
China Recycling Energy Corporation Page 3 of 3 You may contact Jorge L. Bonilla at ( 202) 551-3414 or me at (202) 551-3498 if you have any questions, Sincerely, Linda van Doorn Senior Assistant Chief Accountant
Show Raw Text
January 15, 2008 Mail Stop 4561
By U.S. Mail and facsimile to (212) 219-3604
Mr. Guangyu Wu, Chief Executive Officer China Recycling Energy Corporation 429 Guangdong Road Shanghai, People’s Republic of China 200001
RE: China Recycling Energy Corporation
File No. 000-12536
Form 10-KSB for the year ended December 31, 2006
Forms 10-QSB for the quarters ended March 31, 2007, June 30, 2007 and September 30, 2007
Dear Mr. Wu:
We have reviewed your response letter dated December 14, 2007 and have the
following comments.
Where indicated, we think you should revise your documents in response to these
comments. If you disagree, we will consider your explanation as to why our comment is
inapplicable or a revision is unnecessary. Pl ease be as detailed as necessary in your
explanation. In some of our comments, we may ask you to provide us with additional information so we may better understand your disclosure. After reviewing this
information, we may or may not raise additional comments.
Please understand that the purpose of our re view process is to assist you in your
compliance with the applicable disclosure requirements and to enhance the overall
disclosure in your filing. We look forward to working with you in these respects.
We welcome any questions you may have about our comment or on any other aspect of
our review. Feel free to call us at the tele phone numbers listed at th e end of th is letter.
China Recycling Energy Corporation
Page 2 of 3
Form 10-KSB
Financial Statements
Note 4 – Impairment Write Down Recognized As A Result Of Strategic Review of
Certain Operations, page 9
1. We have read and considered your respons e to comment three. Please revise your
statement of operations to reflect the im pairment loss on property and equipment
and deposit for business acquisition as a charge to earnings in accordance with
paragraph 25 of SFAS 144. Also, please not e that paragraph 15 of SFAS 5, which
was cited in support for your accounting tr eatment, prohibits charging costs or
losses to an appropriation of retained earnings.
Forms 10-QSB for the quarters ended March 31, 2007, June 30, 2007 and September 30,
2007
Financial Statements
Condensed Consolidated Balance Sheet
2. We have read and considered your re sponse to comment six relating to the
amount reported as “Due from a third pa rty.” We noted this amount is trade
related, due from a single debtor, unsecu red and it relates to the mobile phone
distribution business that you discon tinued in May 2007. Also, it appears it
remained uncollected as of September 30, 2007. Please explain to us how you determined that the collection of this receivable was reasonably assured and
accordingly, no allowance was necessary as of September 30, 2007.
3. Also, explain to us how you evaluated th e risks due to this substantial asset
concentration, and how you considered provi ding audited financial statements of
the debtor for an investor’s financial assessment of the Company.
As appropriate, please amend your filings and respond to these comments within
10 business days or tell us when you will provid e us with a response. You may wish to
provide us with marked copies of the amendm ent to expedite our review. Please furnish
a cover letter with your amendment that keys your responses to our comments and provides any requested information. Detailed response letters great ly facilitate our
review. Please submit your cover letter on EDGAR. Please understand that we may have
additional comments after reviewing your amendment and responses to our comments.
China Recycling Energy Corporation
Page 3 of 3
You may contact Jorge L. Bonilla at ( 202) 551-3414 or me at (202) 551-3498 if
you have any questions, Sincerely, Linda van Doorn Senior Assistant Chief Accountant