SEC Comment Letter for Smart Powerr Corp. (CREG) (CIK 0000721693) (CREG) — Dec 4, 2018
Smart Powerr Corp. (CREG) (CIK 0000721693)
Date: Dec. 4, 2018 · CIK: 0000721693 · Accession: 0000000000-18-037147
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Letter
Mail Stop 3561 December 4, 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 October 9 , 2018 File No. 1 -34625
Dear Ms. Gu :
We have reviewed your October 9 , 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 a dditional comments. Unless we note otherwise, our references to prior comments are to comments in our September 24, 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. We object to your accounting for this modification. You elected to estimate variable lease payments and include them in your calculation of minimum lease payments, which directly contradicts the definitio n of
Adeline Gu China Recycling Energy Corporation December 4, 2018 Page 2
minimum lease payments in ASC 840. Please revise your financial statements accordingly.
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 December 4, 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 October 9 , 2018 File No. 1 -34625 Dear Ms. Gu : We have reviewed your October 9 , 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 a dditional comments. Unless we note otherwise, our references to prior comments are to comments in our September 24, 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. We object to your accounting for this modification. You elected to estimate variable lease payments and include them in your calculation of minimum lease payments, which directly contradicts the definitio n of Adeline Gu China Recycling Energy Corporation December 4, 2018 Page 2 minimum lease payments in ASC 840. Please revise your financial statements accordingly. 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