SEC Comment Letter for Smart Powerr Corp. (CREG) (CIK 0000721693) (CREG) — Sep 24, 2018
Smart Powerr Corp. (CREG) (CIK 0000721693)
Date: Sept. 24, 2018 · CIK: 0000721693 · Accession: 0000000000-18-030042
AI Filing Summary & Sentiment
Reasoning
Letter
Mail Stop 3561 September 24, 2018 Adeline Gu Chief Financial Officer China Recycling Energy Corporation 4/F, Tower C Rong Cheng Yun Gu Building Keji 3rd Road, Yanta District Xi’an City, Shaanxi Province China 710075
Re: China Recycling Energy Corporation Form 10-K for the Fiscal Year Ended December 31, 2017 Filed April 13, 2018 Response Dated September 20, 2018 File No. 1 -34625
Dear Ms. Gu :
We have reviewed your September 20, 2018 response to our comment letter and have the following comment s. In some of our comments , we may ask you to provide us with information so we may better understand your disclosure.
Please respond to these comments within ten busine ss days by providing the requested information or advis e us as soon as possible when you will respond. If you do not believe our comments apply to your facts and circumstances, please tell us why in your response.
After reviewing your response to these comments, we may have additional comments. Unless we note otherwise, our references to prior comments are to comments in our September 7, 2018 letter .
Item 8. Financial Statements and Supplementary Data
1. Organization and Description of Business
Erdos TCH – Joint Venture, page F -6
1. We reviewed your response to comment 1. Please explain to us in detail how you concluded the modification did not change the classification of the lease referencing authoritative literature that supports your conclusion. Please also clarify for us whether
Adeline Gu China Recycling Energy Corporation September 24, 2018 Page 2
you considered payments based on actual electricity sold as minimum lease payments when evaluating the modified terms referencing authoritative literature that supports your conclusion. If so, tell us what minimum payments you assu med and how you estimated such amounts. In addition, please explain your accounting conclusions and show us how your financial statements would change had you not considered payments based on actual electricity sold as minimum lease payments. Finally, pl ease explain why you believe ASC 450 -20-25-2 should be considered when evaluating this transaction.
You may contact Adam Phippen, Staff Accountant, at (202) 551 -3336 or me at (202) 551-3344 with any questions.
Sincerely,
/s/ William H. Thompson
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Mail Stop 3561 September 24, 2018 Adeline Gu Chief Financial Officer China Recycling Energy Corporation 4/F, Tower C Rong Cheng Yun Gu Building Keji 3rd Road, Yanta District Xi’an City, Shaanxi Province China 710075 Re: China Recycling Energy Corporation Form 10-K for the Fiscal Year Ended December 31, 2017 Filed April 13, 2018 Response Dated September 20, 2018 File No. 1 -34625 Dear Ms. Gu : We have reviewed your September 20, 2018 response to our comment letter and have the following comment s. In some of our comments , we may ask you to provide us with information so we may better understand your disclosure. Please respond to these comments within ten busine ss days by providing the requested information or advis e us as soon as possible when you will respond. If you do not believe our comments apply to your facts and circumstances, please tell us why in your response. After reviewing your response to these comments, we may have additional comments. Unless we note otherwise, our references to prior comments are to comments in our September 7, 2018 letter . Item 8. Financial Statements and Supplementary Data 1. Organization and Description of Business Erdos TCH – Joint Venture, page F -6 1. We reviewed your response to comment 1. Please explain to us in detail how you concluded the modification did not change the classification of the lease referencing authoritative literature that supports your conclusion. Please also clarify for us whether Adeline Gu China Recycling Energy Corporation September 24, 2018 Page 2 you considered payments based on actual electricity sold as minimum lease payments when evaluating the modified terms referencing authoritative literature that supports your conclusion. If so, tell us what minimum payments you assu med and how you estimated such amounts. In addition, please explain your accounting conclusions and show us how your financial statements would change had you not considered payments based on actual electricity sold as minimum lease payments. Finally, pl ease explain why you believe ASC 450 -20-25-2 should be considered when evaluating this transaction. You may contact Adam Phippen, Staff Accountant, at (202) 551 -3336 or me at (202) 551-3344 with any questions. Sincerely, /s/ William H. Thompson William H. Thompson Accounting Branch Chief Office of Consumer Products