Public Service Enterprise Group Incorporated 80 Park Plaza, Newark, New Jersey 07102-4194 |
 | ||
| August 3, 2017 | ||
VIA EDGAR
William H. Thompson
Accounting Branch Chief
Office of Consumer Products
Division of Corporation Finance
U.S. Securities and Exchange Commission
100 F Street, NE
Washington, DC 20549
| Re: | Public Service Enterprise Group Incorporated |
| Form 10-K for the Fiscal Year Ended December 31, 2016 |
| Filed February 27, 2017 |
| File No. 1-09120 |
Dear Mr. Thompson:
Reference is made to your letter dated July 26, 2017 to Ralph Izzo, President and Chief Executive Officer, Public Service Enterprise Group Incorporated (the “Company” or “we”), setting forth the Staff’s comment on the above-referenced filing (the “Comment Letter”). We are submitting this letter in response to the Staff’s Comment Letter. The headings and numbered paragraph in this letter correspond to the original headings and numbered paragraph in the Comment Letter. For ease of reference, we have repeated the Staff’s comment before our response.
Notes to Consolidated Financial Statements
Note 18. Stock Based Compensation, page 155
| 1. | We note that restricted stock units and performance share units entitle the recipients to dividends. Please tell us if these awards qualify as participating securities as defined in ASC 260-10-20. If so, please tell us what consideration you gave to computing earnings per share under the two-class method. Please refer to ASC 260-10-45-60B. |
The dividend equivalent units related to our restricted stock units and performance share units are forfeitable with the base awards. As a result, these awards would not be considered participating securities and therefore, the two-class method for computing earnings per share would not apply to our restricted stock unit awards and performance share unit awards.
* * * *
Once you have had time to review our response to the Staff’s comment, we would appreciate the opportunity to discuss any additional questions or concerns that you may have. Please feel free to call me at (973) 430-6424.
Sincerely,
/s/ Stuart J. Black
Stuart J. Black
Vice President and Controller
cc:
Ralph Izzo, President and Chief Executive Officer
Daniel Cregg, Executive Vice President and Chief Financial Officer
Tamara Linde, Executive Vice President and General Counsel