SEC Comment Letter for ATMOS ENERGY CORP (ATO) (CIK 0000731802) (ATO) — May 17, 2017
ATMOS ENERGY CORP (ATO) (CIK 0000731802)
Date: May 17, 2017 · CIK: 0000731802 · Accession: 0000000000-17-017393
AI Filing Summary & Sentiment
Letter
Mail Stop 3561 May 17, 2017 Christopher T. Forsythe Chief Financial Officer Atmos Energy Corporation Three Lincoln Centre, Suite 1800 5430 LBJ Freeway Dallas, Texas 75240
Re: Atmos Energy Corporation Form 10-Q for the Quarterly Period Ended March 31, 2017 Response Dated May 4 , 2017 File No s. 1-10042
Dear Mr. Forsythe :
We have reviewed your May 4 , 2017 response to our comment letter and have the following comment . In our comment , we may ask you to provide us with information so we may better understand your disclosure.
Please respond to this comment 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 comment applies to your facts and circumstances, please tell us why in your response.
After reviewing your response to this comment , we may have additional comments. Unless we note otherwise, our references to prior comments are to comments in ou r May 2 , 2017 letter .
Form 10 -Q for the Quarterly Period March 31, 2017
Item2. Management’s Discussion and Analysis of Financial Condition and Results of Operations
Results of Operations Distribution Segment, page 37
1. We note your disclosure on page 38 that you believe gross profit is a better indicator of your financial performance than revenues since increases in the cost of gas are offset by a corresponding increase in revenues. In future filings, please disclose th at gross profit is a
Christopher T. Forsythe Atmos Energy Corporation May 17, 2017 Page 2
non-GAAP financial measure and why management believes the non -GAAP measure provides useful information to investors. Refer to Item 10(e) of Regulation S -K.
You may contact Tony Watson, Accountant, at (202) 551 -3318 or me at (202) 55 1-3344 with any questions .
Sincerely,
/s/ William H. Thompson
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Mail Stop 3561 May 17, 2017 Christopher T. Forsythe Chief Financial Officer Atmos Energy Corporation Three Lincoln Centre, Suite 1800 5430 LBJ Freeway Dallas, Texas 75240 Re: Atmos Energy Corporation Form 10-Q for the Quarterly Period Ended March 31, 2017 Response Dated May 4 , 2017 File No s. 1-10042 Dear Mr. Forsythe : We have reviewed your May 4 , 2017 response to our comment letter and have the following comment . In our comment , we may ask you to provide us with information so we may better understand your disclosure. Please respond to this comment 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 comment applies to your facts and circumstances, please tell us why in your response. After reviewing your response to this comment , we may have additional comments. Unless we note otherwise, our references to prior comments are to comments in ou r May 2 , 2017 letter . Form 10 -Q for the Quarterly Period March 31, 2017 Item2. Management’s Discussion and Analysis of Financial Condition and Results of Operations Results of Operations Distribution Segment, page 37 1. We note your disclosure on page 38 that you believe gross profit is a better indicator of your financial performance than revenues since increases in the cost of gas are offset by a corresponding increase in revenues. In future filings, please disclose th at gross profit is a Christopher T. Forsythe Atmos Energy Corporation May 17, 2017 Page 2 non-GAAP financial measure and why management believes the non -GAAP measure provides useful information to investors. Refer to Item 10(e) of Regulation S -K. You may contact Tony Watson, Accountant, at (202) 551 -3318 or me at (202) 55 1-3344 with any questions . Sincerely, /s/ William H. Thompson William H. Thompson Accounting Branch Chief Office of Consumer Products