SEC Comment Letter for ATMOS ENERGY CORP (ATO) (CIK 0000731802) (ATO) — Mar 19, 2018
ATMOS ENERGY CORP (ATO) (CIK 0000731802)
Date: March 19, 2018 · CIK: 0000731802 · Accession: 0000000000-18-008368
AI Filing Summary & Sentiment
Letter
Mail Stop 3561 March 19, 2018 Christopher T. Forsythe Chief Financial Officer Atmos Energy Corporation Three Lincoln Centre, Suite 1800 5430 LBJ Freeway Dallas, TX 75240
Re: Atmos Energy Corporation Form 10 -K for the Fis cal Year Ended September 30, 2017 Response Dated March 13, 2018 File No. 1-10042
Dear Mr. Forsythe :
We have reviewed your March 13, 2018 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 our March 5, 2018 letter .
Form 10 -K for the Fiscal Year Ended September 30, 2017
Management’s Discussion and Analysis of Financial Condition and Results of Operations
Non-GAAP Financial Measure, page 25
1. We note your response to comment 1 . Please tell us how your proposed presentation of "net revenues" complies with Item 10(e)(1)(ii)(E) of Regulation S -K, which prohibits using titles for non -GAAP measures that are the same as, or confusingly similar to, titles or descriptions used for GAA P financial measures.
Christopher T. Forsythe Atmos Energy Corporation March 19, 2018 Page 2
You may contact Scott Stringer, Staff Accountant, at (202) 551 -3272 or Donna Di Silvio, Staff Accountant, at (202) 551 -3202 if you have questions regarding our comments. Please contact me at (202) 551 -3344 with any other questions.
Sincerely,
/s/ William H. Thompson
Show Raw Text
Mail Stop 3561 March 19, 2018 Christopher T. Forsythe Chief Financial Officer Atmos Energy Corporation Three Lincoln Centre, Suite 1800 5430 LBJ Freeway Dallas, TX 75240 Re: Atmos Energy Corporation Form 10 -K for the Fis cal Year Ended September 30, 2017 Response Dated March 13, 2018 File No. 1-10042 Dear Mr. Forsythe : We have reviewed your March 13, 2018 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 our March 5, 2018 letter . Form 10 -K for the Fiscal Year Ended September 30, 2017 Management’s Discussion and Analysis of Financial Condition and Results of Operations Non-GAAP Financial Measure, page 25 1. We note your response to comment 1 . Please tell us how your proposed presentation of "net revenues" complies with Item 10(e)(1)(ii)(E) of Regulation S -K, which prohibits using titles for non -GAAP measures that are the same as, or confusingly similar to, titles or descriptions used for GAA P financial measures. Christopher T. Forsythe Atmos Energy Corporation March 19, 2018 Page 2 You may contact Scott Stringer, Staff Accountant, at (202) 551 -3272 or Donna Di Silvio, Staff Accountant, at (202) 551 -3202 if you have questions regarding our comments. Please contact me at (202) 551 -3344 with any other questions. Sincerely, /s/ William H. Thompson William H. Thompson Accounting Branch Chief Office of Consumer Products