SEC Comment Letter for Smart Powerr Corp. (CREG) (CIK 0000721693) (CREG) — Jul 25, 2013
Smart Powerr Corp. (CREG) (CIK 0000721693)
Date: July 25, 2013 · CIK: 0000721693 · Accession: 0000000000-13-040876
AI Filing Summary & Sentiment
Reasoning
Letter
July 25 , 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 Amendment No. 1 to Form 10-K for Fiscal Year Ended December 31, 2011 Filed July 18, 2013 File No. 1 -34625
Dear Mr. Chong :
We have reviewed your amendment 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 reques ted 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 reviewi ng any amendment to your filing and the information you provide in response to this comment , we may have additional comments
Amendment No. 1 to Form 10 -K for Fiscal Y ear Ended December 31, 20 11
Item 8. Financial Statements and Supplementary Data, page 51
15. Convertible Notes Payable and Revolving Financing Agreement, page 71
Convertible Note Agreement with China Cinda , page 73
1. Please clarify whether or not the December 9, 2011 Supplemental Agreement to the Notes Purchase Agreement eliminated the conversion feature related to the notes at the time of execution of the agreement. If so, please explain why you have a conversion
David Chong China Recycling Energy Corporation July 25 , 2013 Page 2
feature liability recorded as of December 31, 2011 related to the notes. If not, please tell us if the notes are still convertible and your basis for not recognizing a conversion feature liability as of December 31, 2012. In this regard, we note your disclo sure in Form 10 -K filed April 1, 2013 that you paid h alf of the amounts owed on the first tranche notes o n June 20, 2012 and the remaining half due on November 30, 2012 was extended to a future date.
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
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July 25 , 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 Amendment No. 1 to Form 10-K for Fiscal Year Ended December 31, 2011 Filed July 18, 2013 File No. 1 -34625 Dear Mr. Chong : We have reviewed your amendment 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 reques ted 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 reviewi ng any amendment to your filing and the information you provide in response to this comment , we may have additional comments Amendment No. 1 to Form 10 -K for Fiscal Y ear Ended December 31, 20 11 Item 8. Financial Statements and Supplementary Data, page 51 15. Convertible Notes Payable and Revolving Financing Agreement, page 71 Convertible Note Agreement with China Cinda , page 73 1. Please clarify whether or not the December 9, 2011 Supplemental Agreement to the Notes Purchase Agreement eliminated the conversion feature related to the notes at the time of execution of the agreement. If so, please explain why you have a conversion David Chong China Recycling Energy Corporation July 25 , 2013 Page 2 feature liability recorded as of December 31, 2011 related to the notes. If not, please tell us if the notes are still convertible and your basis for not recognizing a conversion feature liability as of December 31, 2012. In this regard, we note your disclo sure in Form 10 -K filed April 1, 2013 that you paid h alf of the amounts owed on the first tranche notes o n June 20, 2012 and the remaining half due on November 30, 2012 was extended to a future date. 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 Thompson Accounting Branch Chief