SEC Comment Letter for PORTLAND GENERAL ELECTRIC (POR) — Aug 27, 2021
PORTLAND GENERAL ELECTRIC CO /OR/ (POR) (CIK 0000784977)
Date: Aug. 27, 2021 · CIK: 0000784977 · Accession: 0000000000-21-010530
AI Filing Summary & Sentiment
File numbers found in text: 001-05532
Letter
United States securities and exchange commission logo August 27, 2021 James A. Ajello Chief Financial Officer Portland General Electric Company 121 SW Salmon Street Portland, Oregon 97204 Re:Portland General Electric Company Form 10-K for Fiscal Year Ended December 31, 2020 File No. 001-05532-99 Dear Mr. Ajello: We have reviewed your August 17, 2021 response to our comment letter 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. Unless we note otherwise, our references to prior comments are to comments in our August 11, 2021 letter. Form 10-K for Fiscal Year Ended December 31, 2020 Management's Discussion and Analysis of Financial Condition and Results of Operations Results of Operations, page 46 1.We note your response to our prior comment 1. As previously noted, pursuant to Item 10(e)(1)(i)(B) of Regulation S-K, reconciliation of non-GAAP measures should be to the most directly comparable measure calculated and presented in accordance with GAAP. For the non-GAAP gross margin measure you present, the most directly comparable GAAP-basis measure appears to be a fully burdened gross margin that includes depreciation and amortization and any other relevant cost of revenue items. Please revise your disclosure accordingly. In this connection, the illustrative example included in your response appears to provide a reconciliation of your non-GAAP gross margin measure to GAAP-basis revenue.
FirstName LastNameJames A. Ajello Comapany NamePortland General Electric Company August 27, 2021 Page 2 FirstName LastName James A. Ajello Portland General Electric Company August 27, 2021 Page 2 You may contact Jennifer O'Brien, Staff Accountant, at 202-551-3721 or Ethan Horowitz, Accounting Branch Chief, at 202-551-3311 if you have any questions. Sincerely, Division of Corporation Finance Office of Energy & Transportation
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United States securities and exchange commission logo
August 27, 2021
James A. Ajello
Chief Financial Officer
Portland General Electric Company
121 SW Salmon Street
Portland, Oregon 97204
Re:Portland General Electric Company
Form 10-K for Fiscal Year Ended December 31, 2020
File No. 001-05532-99
Dear Mr. Ajello:
We have reviewed your August 17, 2021 response to our comment letter 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. Unless we note otherwise, our references to prior comments are to comments in our
August 11, 2021 letter.
Form 10-K for Fiscal Year Ended December 31, 2020
Management's Discussion and Analysis of Financial Condition and Results of Operations
Results of Operations, page 46
1.We note your response to our prior comment 1. As previously noted, pursuant to Item
10(e)(1)(i)(B) of Regulation S-K, reconciliation of non-GAAP measures should be to the
most directly comparable measure calculated and presented in accordance with GAAP.
For the non-GAAP gross margin measure you present, the most directly comparable
GAAP-basis measure appears to be a fully burdened gross margin that includes
depreciation and amortization and any other relevant cost of revenue items. Please revise
your disclosure accordingly. In this connection, the illustrative example included in your
response appears to provide a reconciliation of your non-GAAP gross margin measure to
GAAP-basis revenue.
FirstName LastNameJames A. Ajello
Comapany NamePortland General Electric Company
August 27, 2021 Page 2
FirstName LastName
James A. Ajello
Portland General Electric Company
August 27, 2021
Page 2
You may contact Jennifer O'Brien, Staff Accountant, at 202-551-3721 or Ethan
Horowitz, Accounting Branch Chief, at 202-551-3311 if you have any questions.
Sincerely,
Division of Corporation Finance
Office of Energy & Transportation