SEC Comment Letter for Smart Powerr Corp. (CREG) (CIK 0000721693) (CREG) — Feb 12, 2013
Smart Powerr Corp. (CREG) (CIK 0000721693)
Date: Feb. 12, 2013 · CIK: 0000721693 · Accession: 0000000000-13-007954
AI Filing Summary & Sentiment
Reasoning
Referenced dates: January 23, 2013
Letter
February 7 , 2013 Via E-mail David Chong Chief Financial Officer China Recycling Energy Corporation 12/F, Tower A Chang An International Building No. 88 Nan Guan Zheng Jie Xi’an City, Shaanxi Province China
Re: China Recycling Energy Corporation Form 10-K for Fiscal Year Ended December 31, 2011 Filed March 22, 2012 Response dated January 30 , 2013 File No. 1 -34625
Dear Mr. Fortunato :
We have reviewed your response dated January 30 , 2013 and have the following additional comment . In our comment , we may ask you to provide us with information so we may better understand your disclosure.
Please respond to this letter within ten business days by amending your filing, by providing the requested information, or by advising us when you will provide the requested response. If you do not believe our comment applies to your facts and circumstances or do not believe an amendment is appropriate, please tell us why in your response.
After reviewing any amendment to your filing and the information you provide in response to this comment , we may have additional comments.
Form 10 -K for Fiscal Y ear Ended December 31, 20 11
Item 8. Financial Statements and Supplementary Da ta, page 50
2. Summary of Significant Accounting Policies, page 57
17. Shareholders’ Equity, page 78
1. We reviewed your response to comment three in our letter dated January 23, 2013. If you were initially obligated to issue a maximum of 2,941,176 shares under the agreement then it appears the guidance in ASC 815 -40 may have been applicable. As such, please
David Chong China Recycling Energy Corporation February 7 , 2013 Page 2
provide us with your detailed analysis of the guidance in ASC 815 -40-25-1 throu gh ASC 815-40-25-35 related to your initial accounting for the agreement.
You may contact Tony Watson, Accountant, at (202) 551 -3318 if you have questions regarding our comment . Please contact me at (202) 551 -3344 with any other questions.
Sincere ly,
/s/ William H. Thompson
William H. Thompson Accounting Branch Chief
Show Raw Text
February 7 , 2013 Via E-mail David Chong Chief Financial Officer China Recycling Energy Corporation 12/F, Tower A Chang An International Building No. 88 Nan Guan Zheng Jie Xi’an City, Shaanxi Province China Re: China Recycling Energy Corporation Form 10-K for Fiscal Year Ended December 31, 2011 Filed March 22, 2012 Response dated January 30 , 2013 File No. 1 -34625 Dear Mr. Fortunato : We have reviewed your response dated January 30 , 2013 and have the following additional comment . In our comment , we may ask you to provide us with information so we may better understand your disclosure. Please respond to this letter within ten business days by amending your filing, by providing the requested information, or by advising us when you will provide the requested response. If you do not believe our comment applies to your facts and circumstances or do not believe an amendment is appropriate, please tell us why in your response. After reviewing any amendment to your filing and the information you provide in response to this comment , we may have additional comments. Form 10 -K for Fiscal Y ear Ended December 31, 20 11 Item 8. Financial Statements and Supplementary Da ta, page 50 2. Summary of Significant Accounting Policies, page 57 17. Shareholders’ Equity, page 78 1. We reviewed your response to comment three in our letter dated January 23, 2013. If you were initially obligated to issue a maximum of 2,941,176 shares under the agreement then it appears the guidance in ASC 815 -40 may have been applicable. As such, please David Chong China Recycling Energy Corporation February 7 , 2013 Page 2 provide us with your detailed analysis of the guidance in ASC 815 -40-25-1 throu gh ASC 815-40-25-35 related to your initial accounting for the agreement. You may contact Tony Watson, Accountant, at (202) 551 -3318 if you have questions regarding our comment . Please contact me at (202) 551 -3344 with any other questions. Sincere ly, /s/ William H. Thompson William H. Thompson Accounting Branch Chief