SEC Comment Letter for Smart Powerr Corp. (CREG) (CIK 0000721693) (CREG) — Apr 17, 2013
Smart Powerr Corp. (CREG) (CIK 0000721693)
Date: April 17, 2013 · CIK: 0000721693 · Accession: 0000000000-13-020696
AI Filing Summary & Sentiment
Reasoning
Referenced dates: March 28, 2013
Letter
April 17 , 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 April 8 , 2013 File No. 1 -34625
Dear Mr. Chong :
We have reviewed your response dated April 8, 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 re quested 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 rev iewing 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 Data, page 50
17. Shareholders’ Equity, page 78
1. We reviewed your response to the comment in our letter dated March 28, 2013. We do not believe the guidance in ASC 450 should be applied to subsequently measure the instrument you initially recorded using the guidance in ASC 480. As such, please revise your financial statements to subsequently measure the instrument in accordance with the measurement guidance in ASC 480 -10-35.
David Chong China Recycling Energy Corporation April 17 , 2013 Page 2
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.
Sincerely,
/s/ William H. Thompson
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April 17 , 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 April 8 , 2013 File No. 1 -34625 Dear Mr. Chong : We have reviewed your response dated April 8, 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 re quested 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 rev iewing 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 Data, page 50 17. Shareholders’ Equity, page 78 1. We reviewed your response to the comment in our letter dated March 28, 2013. We do not believe the guidance in ASC 450 should be applied to subsequently measure the instrument you initially recorded using the guidance in ASC 480. As such, please revise your financial statements to subsequently measure the instrument in accordance with the measurement guidance in ASC 480 -10-35. David Chong China Recycling Energy Corporation April 17 , 2013 Page 2 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. Sincerely, /s/ William H. Thompson William Thompson Accounting Branch Chief