SecProbe.io

Filing text and metadata
Intelligence Terminal Search Probe Scores Topics IPO Watchlist Monthly Activity About API

SEC Comment Letter for CENTRUS ENERGY CORP (LEU) (CIK 0001065059) (LEU) — Jan 20, 2022

CENTRUS ENERGY CORP (LEU) (CIK 0001065059)
Date: Jan. 20, 2022 · CIK: 0001065059 · Accession: 0000000000-22-000728

AI Filing Summary & Sentiment

File numbers found in text: 001-14287

Referenced dates: January 4, 2022

Date
January 20, 2022
Author
Not clearly detected
Form
UPLOAD
Company
CENTRUS ENERGY CORP (LEU) (CIK 0001065059)

Letter

United States securities and exchange commission logo January 20, 2022 Philip Strawbridge Chief Financial Officer Centrus Energy Corp. 6901 Rockledge Drive, Suite 800 Bethesda, MD 20817 Re:Centrus Energy Corp. Form 10-K for the Fiscal Year ended December 31, 2020 Filed March 22, 2021 Form 10-Q for the Nine Months ended September 30, 2021 Filed November 12, 2021 File No. 001-14287 Dear Mr. Strawbridge: We have reviewed your January 4, 2022 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 December 20, 2021 letter. Response Letter Dated January 4, 2022 Form 10-K for the Fiscal Year ended December 31, 2020 Management's Discussion and Analysis of Financial Condition and Results of Operations Results of Operations, page 52 1.The revised disclosure provided in response to comment 1 states that the presentation of non-GAAP measures is useful to investors because it provides a more accurate reflection of management’s assessment of your ongoing operating performance. Please further revise your disclosure as this language appears to be inconsistent with the prominence requirements per Item 10(e)(1)(i)(A) of Regulation S-K.

FirstName LastNamePhilip Strawbridge Comapany NameCentrus Energy Corp. January 20, 2022 Page 2 FirstName LastName Philip Strawbridge Centrus Energy Corp. January 20, 2022 Page 2 Financial Statements Consolidated Statements of Operations and Comprehensive Income, page 76 2.We note from your response to prior comment 2 that the claim settlement represents consideration paid for the existing "take or pay" provisions under a SWU customer supply contract. Tell us the periods for which the settlement amount recognized relates and quantify any revenue previously recognized for this contract in those periods, including information about amounts invoiced when the customer failed to submit an order meeting its annual purchase obligations. As part of your response, provide us a detailed analysis of your accounting treatment with references to the relevant authoritative guidance.

In addition, clarify the portion of your response stating that the amount recognized was for the settlement of a breach of a contract as disclosure in your filing states that the claims are related to damages arising from the rejection and breach of a long-term contract. Form 10-Q for the Nine Months ended September 30, 2021 Financial Statements Condensed Consolidated Statements of Operations and Comprehensive Income, page 5 3.Your response to prior comment 3 states that the settlement proceeds represent the contractual consideration of a service contract with the U.S. Department of Energy and are recorded as revenue in accordance with FASB ASC 606. Provide us with a detailed analysis of your accounting treatment with citations to the relevant authoritative guidance. As part of your response, tell us about your accounting for this contract in prior periods, specifically with regard to amounts related to expected reimbursements for costs including pension and postretirement benefits costs you incurred. If any amounts were previously recognized, provide us with information describing and quantifying the amounts recognized by year. In addition, clarify the nature of the settlement of claims referred to in your response.

You may contact Wei Lu, Staff Accountant at (202) 551-3725 or Ethan Horowitz, Accounting Branch Chief at (202) 551-3311, if you have questions regarding the comments. Sincerely, Division of Corporation Finance Office of Energy & Transportation

Show Raw Text
United States securities and exchange commission logo
January 20, 2022
Philip Strawbridge
Chief Financial Officer
Centrus Energy Corp.
6901 Rockledge Drive, Suite 800
Bethesda, MD 20817
Re:Centrus Energy Corp.
Form 10-K for the Fiscal Year ended December 31, 2020
Filed March 22, 2021
Form 10-Q for the Nine Months ended September 30, 2021
Filed November 12, 2021
File No. 001-14287
Dear Mr. Strawbridge:
            We have reviewed your January 4, 2022 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
December 20, 2021 letter.
Response Letter Dated January 4, 2022
Form 10-K for the Fiscal Year ended December 31, 2020
Management's Discussion and Analysis of Financial Condition and Results of Operations
Results of Operations, page 52
1.The revised disclosure provided in response to comment 1 states that the presentation of
non-GAAP measures is useful to investors because it provides a more accurate reflection
of management’s assessment of your ongoing operating performance.  Please further
revise your disclosure as this language appears to be inconsistent with the prominence
requirements per Item 10(e)(1)(i)(A) of Regulation S-K.

 FirstName LastNamePhilip Strawbridge
 Comapany NameCentrus Energy Corp.
 January 20, 2022 Page 2
 FirstName LastName
Philip Strawbridge
Centrus Energy Corp.
January 20, 2022
Page 2
Financial Statements
Consolidated Statements of Operations and Comprehensive Income, page 76
2.We note from your response to prior comment 2 that the claim settlement represents
consideration paid for the existing "take or pay" provisions under a SWU customer supply
contract.  Tell us the periods for which the settlement amount recognized relates and
quantify any revenue previously recognized for this contract in those periods, including
information about amounts invoiced when the customer failed to submit an order meeting
its annual purchase obligations.  As part of your response, provide us a detailed analysis of
your accounting treatment with references to the relevant authoritative guidance.

In addition, clarify the portion of your response stating that the amount recognized was for
the settlement of a breach of a contract as disclosure in your filing states that the claims
are related to damages arising from the rejection and breach of a long-term contract.
Form 10-Q for the Nine Months ended September 30, 2021
Financial Statements
Condensed Consolidated Statements of Operations and Comprehensive Income, page 5
3.Your response to prior comment 3 states that the settlement proceeds represent the
contractual consideration of a service contract with the U.S. Department of Energy and are
recorded as revenue in accordance with FASB ASC 606.  Provide us with a detailed
analysis of your accounting treatment with citations to the relevant authoritative guidance.
As part of your response, tell us about your accounting for this contract in prior periods,
specifically with regard to amounts related to expected reimbursements for costs including
pension and postretirement benefits costs you incurred.  If any amounts were previously
recognized, provide us with information describing and quantifying the amounts
recognized by year.  In addition, clarify the nature of the settlement of claims referred to
in your response.

            You may contact Wei Lu, Staff Accountant at (202) 551-3725 or Ethan Horowitz,
Accounting Branch Chief at (202) 551-3311, if you have questions regarding the comments.
Sincerely,
Division of Corporation Finance
Office of Energy & Transportation