SEC Comment Letter for EXELON CORP (EXC) (CIK 0001109357) (EXC) — Jul 31, 2017
EXELON CORP (EXC) (CIK 0001109357)
Date: July 31, 2017 · CIK: 0001109357 · Accession: 0000000000-17-026805
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Letter
Mail Stop 3561 July 31 , 2017 Duane M. DesParte Senior Vice President & Corporate Controller Exelon Corporation 10 South Dearborn Street P.O. Box 805379 Chicago, Illinois 60680 -5379
Re: Exelon Corporation Form 10-K for Fiscal Year Ended December 31, 2016 Filed February 13 , 2017 Form 8 -K Filed February 8, 2017 Response Dated July 19, 2017 File No. 1-16169
Dear Mr. Desparte :
We have reviewed your July 19, 2017 response to our comment letter and have the following comment. In some of our comments , 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.
Form 8 -K Filed February 8, 2017
1. We reviewed your response to comment 5. We still believe that such presentation is inconsistent with the updated Compliance and Disclosure Interpretations issued on May 17, 2016. In that regard, please confirm to us that you will discontinue the presentation of a full non -GAAP income statement when reconciling non -GAAP measures to the most directly comparable GAAP measures in your future earnings releases.
Duane M. DesParte Exelon Corporation July 31, 2017 Page 2
You may contact Yolanda Guo badia at (202) 551 -3562 or me at (202) 551 -3344 if you have questions regarding our comment on the financial statements and related matters. Please contact Katherine Bagley at (202) 551 -2545 or Mara Ransom at (202) 551 -3264 with any other questions.
Sincerely,
/s/ William H. Thompson
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Mail Stop 3561 July 31 , 2017 Duane M. DesParte Senior Vice President & Corporate Controller Exelon Corporation 10 South Dearborn Street P.O. Box 805379 Chicago, Illinois 60680 -5379 Re: Exelon Corporation Form 10-K for Fiscal Year Ended December 31, 2016 Filed February 13 , 2017 Form 8 -K Filed February 8, 2017 Response Dated July 19, 2017 File No. 1-16169 Dear Mr. Desparte : We have reviewed your July 19, 2017 response to our comment letter and have the following comment. In some of our comments , 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. Form 8 -K Filed February 8, 2017 1. We reviewed your response to comment 5. We still believe that such presentation is inconsistent with the updated Compliance and Disclosure Interpretations issued on May 17, 2016. In that regard, please confirm to us that you will discontinue the presentation of a full non -GAAP income statement when reconciling non -GAAP measures to the most directly comparable GAAP measures in your future earnings releases. Duane M. DesParte Exelon Corporation July 31, 2017 Page 2 You may contact Yolanda Guo badia at (202) 551 -3562 or me at (202) 551 -3344 if you have questions regarding our comment on the financial statements and related matters. Please contact Katherine Bagley at (202) 551 -2545 or Mara Ransom at (202) 551 -3264 with any other questions. Sincerely, /s/ William H. Thompson William H. Thompson Accounting Branch Chief Office of Consumer Products