SEC Comment Letter for Smart Powerr Corp. (CREG) (CIK 0000721693) (CREG) — Mar 20, 2013
Smart Powerr Corp. (CREG) (CIK 0000721693)
Date: March 20, 2013 · CIK: 0000721693 · Accession: 0000000000-13-014843
AI Filing Summary & Sentiment
Reasoning
Referenced dates: March 4, 2013
Letter
March 20 , 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 March 19 , 2013 File No. 1 -34625
Dear Mr. Chong :
We have reviewed your response dated March 19, 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 th e 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.
Item 8. Financial Statements and Supplementary Data, page 50
17. Shareholders’ Equity, page 78
1. We reviewed your response to the comment in our letter dated March 4, 2013. You did not provide us with your analysis at inception of all possible outcomes you considered in your evaluation of which component is predominate. In this regard, it appears to us there are two possible outcomes to consider. The first outcome being whether or not your stock price would be above $4 per share when you settled the agreement and the second outcome being whether or not your stock price would be below $4 per share wh en you settled the agreement. The analysis you provide should be both quantitative and
David Chong China Recycling Energy Corporation March 20 , 2013 Page 2
qualitative. The quantitative part of the analysis should consider your stock price and volatility and the qualitative part should consider any other pertinent informa tion you considered. Based on these quantitative and qualitative factors, you should tell us the likelihood of achieving both outcomes (i.e., 20%, 50% or 90%).
You may contact Tony Watson, Accountant, at (202) 551 -3318 if you have questions regarding our comments. Please contact me at (202) 551 -3344 with any other questions.
Sincerely,
/s/ William H. Thompson
Show Raw Text
March 20 , 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 March 19 , 2013
File No. 1 -34625
Dear Mr. Chong :
We have reviewed your response dated March 19, 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 th e 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.
Item 8. Financial Statements and Supplementary Data, page 50
17. Shareholders’ Equity, page 78
1. We reviewed your response to the comment in our letter dated March 4, 2013. You did
not provide us with your analysis at inception of all possible outcomes you considered in
your evaluation of which component is predominate. In this regard, it appears to us there
are two possible outcomes to consider. The first outcome being whether or not your
stock price would be above $4 per share when you settled the agreement and the second
outcome being whether or not your stock price would be below $4 per share wh en you
settled the agreement. The analysis you provide should be both quantitative and
David Chong
China Recycling Energy Corporation
March 20 , 2013
Page 2
qualitative. The quantitative part of the analysis should consider your stock price and
volatility and the qualitative part should consider any other pertinent informa tion you
considered. Based on these quantitative and qualitative factors, you should tell us the
likelihood of achieving both outcomes (i.e., 20%, 50% or 90%).
You may contact Tony Watson, Accountant, at (202) 551 -3318 if you have questions
regarding our comments. Please contact me at (202) 551 -3344 with any other questions.
Sincerely,
/s/ William H. Thompson
William H. Thompson
Accounting Branch Chief