SEC Comment Letter for CENTERPOINT ENERGY INC (CNP) (CIK 0001130310) (CNP) — Jun 30, 2005
CENTERPOINT ENERGY INC (CNP) (CIK 0001130310)
Date: June 30, 2005 · CIK: 0001130310 · Accession: 0000000000-05-033585
AI Filing Summary & Sentiment
File numbers found in text: 333-123182
Referenced dates: June 9, 2005
Letter
Mail Stop 3561 June 30, 2005 Rufus S. Scott Vice President, Deputy General Counsel and Assistant Corporate Secretary CenterPoint Energy, Inc. 1111 Louisiana Houston, Texas 77002 CenterPoint Energy Houston Electric, LLC Form 10-K for the fiscal year ended December 31, 2004 Filed March 24, 2005 File No. 1-03187
Re: CenterPoint Energy, Inc. Amendment No. 2 to Registration Statement on Form S-4 Filed May 22, 2005 File No. 333-123182
Dear Mr. Scott:
We have reviewed your amended filing and we have the following comment. Where indicated, we think you should revise your document in response to this comment. If you disagree, we will consider your explanation as to why our comment is inapplicable or a revision is unnecessary. Please be as detailed as necessary in your explanation. In our comment, we may ask you to provide us with information so we may better understand your disclosure. After reviewing this information, we may or may not raise additional comments. Feel free to call us at the telephone numbers listed at the end of this letter.
CenterPoint Energy Houston, LLC - Form 10-K for the fiscal year ended December 31, 2004 1. Please refer to comment 6 in our letter dated June 9, 2005. Provide to us the calculations supporting the $226 million income recognition related to the debt component of the true-up balance. In this regard, your historical financial statements appear to support a lower debt-to-equity ratio than what was actually recorded. We may have further comment.
* * * * *
You may contact Robert Babula, Staff Accountant, at (202) 551- 3339 or Michael Moran, Accounting Branch Chief, at (202) 551-3841 if you have questions regarding the financial statements and related matters. Please contact Pradip Bhaumik, Attorney-Advisor, at (202) 551-3333, Ellie Quarles, Special Counsel, at (202) 551-3238, or me at (202) 551-3720 with any questions.
Sincerely,
H. Christopher Owings
Assistant Director
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<TEXT>
Mail Stop 3561
June 30, 2005
Rufus S. Scott
Vice President, Deputy General Counsel
and Assistant Corporate Secretary
CenterPoint Energy, Inc.
1111 Louisiana
Houston, Texas 77002
Re: CenterPoint Energy, Inc.
Amendment No. 2 to Registration Statement on Form S-4
Filed May 22, 2005
File No. 333-123182
CenterPoint Energy Houston Electric, LLC
Form 10-K for the fiscal year ended December 31, 2004
Filed March 24, 2005
File No. 1-03187
Dear Mr. Scott:
We have reviewed your amended filing and we have the
following
comment. Where indicated, we think you should revise your
document
in response to this comment. If you disagree, we will consider
your
explanation as to why our comment is inapplicable or a revision is
unnecessary. Please be as detailed as necessary in your
explanation.
In our comment, we may ask you to provide us with information so
we
may better understand your disclosure. After reviewing this
information, we may or may not raise additional comments. Feel
free
to call us at the telephone numbers listed at the end of this
letter.
CenterPoint Energy Houston, LLC - Form 10-K for the fiscal year
ended
December 31, 2004
1. Please refer to comment 6 in our letter dated June 9, 2005.
Provide to us the calculations supporting the $226 million income
recognition related to the debt component of the true-up balance.
In
this regard, your historical financial statements appear to
support a
lower debt-to-equity ratio than what was actually recorded. We
may
have further comment.
* * * * *
You may contact Robert Babula, Staff Accountant, at (202)
551-
3339 or Michael Moran, Accounting Branch Chief, at (202) 551-3841
if
you have questions regarding the financial statements and related
matters. Please contact Pradip Bhaumik, Attorney-Advisor, at
(202)
551-3333, Ellie Quarles, Special Counsel, at (202) 551-3238, or me
at
(202) 551-3720 with any questions.
Sincerely,
H. Christopher Owings
Assistant Director
cc: Gerald M. Spedale, Esq.
Baker Botts L.L.P.
Fax: (713) 229-1522
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Rufus S. Scott
CenterPoint Energy, Inc. et al.
June 30, 2005
Page 2
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