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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.
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.
FirstName LastNamePhilip Strawbridge Sincerely,
Comapany NameCentrus Energy Corp.
Division of
Corporation Finance
January 20, 2022 Page 2 Office of Energy
& Transportation
FirstName LastName