SEC Comment Letter for ATMOS ENERGY CORP (ATO) (CIK 0000731802) (ATO) — Jan 21, 2020
ATMOS ENERGY CORP (ATO) (CIK 0000731802)
Date: Jan. 21, 2020 · CIK: 0000731802 · Accession: 0000000000-20-000503
AI Filing Summary & Sentiment
File numbers found in text: 001-10042
Letter
January 21, 2020 Christopher T. Forsythe Senior Vice President and Chief Financial Officer Atmos Energy Corporation 1800 Three Lincoln Centre 5430 LBJ Freeway Dallas, Texas 75240 Re:Atmos Energy Corporation Form 10-K for the Fiscal Year Ended September 30, 2019 Filed November 12, 2019 File No. 001-10042 Dear Mr. Forsythe: We have limited our review of your filing to the financial statements and related disclosures and have the following comments. 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 business days by providing the requested information or advise 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 additional comments. Form 10-K for the Fiscal Year Ended September 30, 2019 Selected Financial Data, page 21 1.Please label “Contribution Margin” as a non-GAAP measure and present the disclosures and reconciliation required by Item 10(e)(1)(i) of Regulation S-K. Management's Discussion and Analysis of Financial Condition and Results of Operations Non-GAAP Financial Measures, page 25 2.Please present a reconciliation for your contribution margin non-GAAP measure. In doing so, reconcile this measure to the most directly comparable GAAP measure of gross margin. If you do not believe gross margin that includes depreciation and amortization is the most directly comparable GAAP measure, please tell us why in your response. Refer to Item 10(e)(1)(i)(B) of Regulation S-K.
FirstName LastNameChristopher T. Forsythe Comapany NameAtmos Energy Corporation January 21, 2020 Page 2 FirstName LastName Christopher T. Forsythe Atmos Energy Corporation January 21, 2020 Page 2 In closing, we remind you that the company and its management are responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the staff. You may contact Yong Kim, Staff Accountant, at 202-551-3323 or Gus Rodriguez, Accounting Branch Chief, at 202-551-3752 with any questions.
Sincerely,
Division of Corporation Finance
Office of Energy & Transportation
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January 21, 2020
Christopher T. Forsythe
Senior Vice President and Chief Financial Officer
Atmos Energy Corporation
1800 Three Lincoln Centre
5430 LBJ Freeway
Dallas, Texas 75240
Re:Atmos Energy Corporation
Form 10-K for the Fiscal Year Ended September 30, 2019
Filed November 12, 2019
File No. 001-10042
Dear Mr. Forsythe:
We have limited our review of your filing to the financial statements and related
disclosures and have the following comments. 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 business days by providing the requested
information or advise 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 additional comments.
Form 10-K for the Fiscal Year Ended September 30, 2019
Selected Financial Data, page 21
1.Please label “Contribution Margin” as a non-GAAP measure and present the disclosures
and reconciliation required by Item 10(e)(1)(i) of Regulation S-K.
Management's Discussion and Analysis of Financial Condition and Results of Operations
Non-GAAP Financial Measures, page 25
2.Please present a reconciliation for your contribution margin non-GAAP measure. In
doing so, reconcile this measure to the most directly comparable GAAP measure of gross
margin. If you do not believe gross margin that includes depreciation and amortization is
the most directly comparable GAAP measure, please tell us why in your response. Refer
to Item 10(e)(1)(i)(B) of Regulation S-K.
FirstName LastNameChristopher T. Forsythe
Comapany NameAtmos Energy Corporation
January 21, 2020 Page 2
FirstName LastName
Christopher T. Forsythe
Atmos Energy Corporation
January 21, 2020
Page 2
In closing, we remind you that the company and its management are responsible for the
accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or
absence of action by the staff.
You may contact Yong Kim, Staff Accountant, at 202-551-3323 or Gus Rodriguez,
Accounting Branch Chief, at 202-551-3752 with any questions.
Sincerely,
Division of Corporation Finance
Office of Energy & Transportation