SEC Company Response from Smart Powerr Corp. (CREG) (CIK 0000721693) (CREG) — Mar 7, 2019
Smart Powerr Corp. (CREG) (CIK 0000721693)
Date: March 7, 2019 · CIK: 0000721693 · Accession: 0001213900-19-003710
AI Filing Summary & Sentiment
Reasoning
Referenced dates: February 28, 2019
Letter
Via EDGAR United States Securities and Exchange Commission Division of Corporation Finance Office of Consumer Products Form 10-K for the Fiscal Year Ended December 31, 2017 Filed April 13, 2018 Responses Dated March 5, 2019 File No. 1-34625
Dear Mr. Thompson:
China Recycling Energy Corporation (“CREG” or the “Company” and sometimes referred to as “we” or “our”) is filing a response to the SEC Comment Letter, dated March 6, 2019 (the “Comment Letter”), in connection with complying with the issues and outstanding disclosure items set forth therein. For convenience of reference, we have included in this response letter the same caption and paragraph numbers, as well as the text of the comments, set forth in the Comment Letter followed by our responses thereto.
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 requested, please explain to us why accounting for the modified lease as an operating lease is appropriate.
Response: The Company has reconsidered the modified lease, and concluded it is not an operating lease, but is a sales-type lease because it has bargain purchase option. However, since the rental payment is variable and depending on actual electricity generated, it is a contingent rental income, and accordingly, the future net investment receivable as of the lease modification date will be written off.
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 non-operating expense.
Response: we will record the impairment loss of net investment receivable as operating expense.
If you have any further comments or require any further information or if any questions should arise in connection with this submission, please call Mr. Jeffrey Li at (202) 298-1735 or Ms. Chelsea Anderson at (206) 816-1312 at Garvey Schubert Barer, P.C.
Very
truly yours,
/s/
Guohua Ku
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CORRESP
1
filename1.htm
March
7, 2019
Via
EDGAR
United
States Securities and Exchange Commission
Division
of Corporation Finance
100 F Street, NE
Washington, D.C. 20549-0405
Attn: William H. Thompson, Accounting Branch Chief
Office
of Consumer Products
Re:
China Recycling Energy Corporation
Form
10-K for the Fiscal Year Ended December 31, 2017
Filed
April 13, 2018
Responses
Dated March 5, 2019
File
No. 1-34625
Dear
Mr. Thompson:
China
Recycling Energy Corporation (“CREG” or the “Company” and sometimes referred to as “we” or
“our”) is filing a response to the SEC Comment Letter, dated March 6, 2019 (the “Comment Letter”), in
connection with complying with the issues and outstanding disclosure items set forth therein. For convenience of reference, we
have included in this response letter the same caption and paragraph numbers, as well as the text of the comments, set forth in
the Comment Letter followed by our responses thereto.
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
requested, please explain to us why accounting for the modified lease as an operating
lease is appropriate.
Response:
The Company has reconsidered the modified lease, and concluded it is not an operating lease, but is a sales-type lease because
it has bargain purchase option. However, since the rental payment is variable and depending on actual electricity generated, it
is a contingent rental income, and accordingly, the future net investment receivable as of the lease modification date will be
written off.
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 non-operating expense.
Response:
we will record the impairment loss of net investment receivable as operating expense.
If
you have any further comments or require any further information or if any questions should arise in connection with this submission,
please call Mr. Jeffrey Li at (202) 298-1735 or Ms. Chelsea Anderson at (206) 816-1312 at Garvey Schubert Barer, P.C.
Very
truly yours,
/s/
Guohua Ku
Guohua
Ku
Chief
Executive Officer
China
Recycle Energy Corporation