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United States securities and exchange commission logo
September 7, 2022
Ke Chen
Chief Financial Officer
ReneSola Ltd
3rd Floor, 850 Canal St.
Stamford, CT 06902
Re: ReneSola Ltd
Form 20-F for the
Year Ended December 31, 2021
Filed April 29,
2022
Form 20-F/A for the
Year Ended December 31, 2021
Filed August 23,
2022
CORRESP filed
August 23, 2022
File No. 001-33911
Dear Mr. Chen:
We have reviewed your August 23, 2022 response to our comment
letter and have the
following comment. In our comment, we may ask you to provide us with
information so we may
better understand your disclosure.
Please respond to this comment 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
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. Unless we note otherwise, our references to prior comments are
to comments in our
August 9, 2022 letter.
Form 20-F/A for the Year Ended December 31, 2021
Item 5. Operating and Financial Review and Prospects
Non-GAAP Financial Measures, page 93
1. We have reviewed your
response to prior comment 12. We continue to believe that the
adjustments related to
allowances for credit losses and cancellation of project assets
appear to be normal
operating expenses related to your business and should not be
eliminated from
non-GAAP performance measures. Please either remove the adjustments
from your non-GAAP
performance measures or provide us with a comprehensive
response that clearly
explains the specific nature of these expenses and why eliminating
Ke Chen
ReneSola Ltd
September 7, 2022
Page 2
these expenses from non-GAAP performance measures is appropriate
pursuant to
Question 100.01 of the SEC's Non-GAAP Financial Measures Compliance
and Disclosure
Interpretations. In this regard, we note the following:
You indicate that the allowances for credit losses adjustment
relates to "allowances
related to related party receivables that arises from Company
spin-off events, the one-
off credit losses from the advance payment on land development,
which after
conduct[ing] further studies and does not have any future
development
opportunities." Please clarify what you mean by "allowances
related to related party
receivables that arises from Company spin-off events." Regarding
your statement
that the expenses include "one off credit losses from the advance
payment on land
development...", please clarify if the expenses relate to the
write-off of land advances,
and if true, tell us why you believe it is appropriate to
identify these expenses as
allowances for credit losses; and
We note that the cancellation of project assets "is mainly due to
some environmental
issues encountered during the projects development process, which
resulted in the
Company unable to finish such projects." It appears to us that
encountering issues
while completing certain projects is a normal cost of business.
Additionally, we note
that you have included this adjustment in each period presented.
As such, it is
unclear as to why or how you view these expenses as non-recurring
in nature.
You may contact Jeffrey Gordon at 202-551-3866 or Kevin Stertzel at
202-551-
3723 with any questions.
FirstName LastNameKe Chen Sincerely,
Comapany NameReneSola Ltd
Division of
Corporation Finance
September 7, 2022 Page 2 Office of
Manufacturing
FirstName LastName