SEC Comment Letter for Smart Powerr Corp. (CREG) (CIK 0000721693) (CREG) — Mar 6, 2019
Smart Powerr Corp. (CREG) (CIK 0000721693)
Date: March 6, 2019 · CIK: 0000721693 · Accession: 0000000000-19-003980
AI Filing Summary & Sentiment
Reasoning
Referenced dates: February 28, 2019
Letter
Mail Stop 3561 March 6 , 2019 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 March 5, 2019 File No. 1 -34625
Dear Ms. Gu :
We have reviewed your March 5, 2019 response s 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 request ed 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 additiona l comments. Unless we note otherwise, our references to prior comments are to comments in our February 28, 2019 letter .
Adeline Gu China Recycling Energy Corporation March 6, 2019 Page 2
Form 10 -K for the Fiscal Year Ended December 31, 2017
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 in our letter dated February 28, 2019. We did not communicate any position regarding the classification of the modified lease. As previously requeste d, please explain to us why accounting for the modified lease as an operating lease is appropriate.
Response Dated February 22, 2019
2. We reviewed your response to comment 2 in our letter dated February 28, 2019. We understand that the impairment charge was classified as non -operating expense. However, it appears the impairment charge should be classified as an operating expense. As previously requested, please tell us your basis for classifying the “Impairment loss of net investment receivable” as a no n-operating expense.
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 March 6 , 2019 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 March 5, 2019 File No. 1 -34625 Dear Ms. Gu : We have reviewed your March 5, 2019 response s 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 request ed 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 additiona l comments. Unless we note otherwise, our references to prior comments are to comments in our February 28, 2019 letter . Adeline Gu China Recycling Energy Corporation March 6, 2019 Page 2 Form 10 -K for the Fiscal Year Ended December 31, 2017 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 in our letter dated February 28, 2019. We did not communicate any position regarding the classification of the modified lease. As previously requeste d, please explain to us why accounting for the modified lease as an operating lease is appropriate. Response Dated February 22, 2019 2. We reviewed your response to comment 2 in our letter dated February 28, 2019. We understand that the impairment charge was classified as non -operating expense. However, it appears the impairment charge should be classified as an operating expense. As previously requested, please tell us your basis for classifying the “Impairment loss of net investment receivable” as a no n-operating expense. 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