March 6, 2020

Fabian Souza
Senior Vice President and Corporate Controller
EXELON CORP
10 South Dearborn Street
P.O. Box 805379
Chicago, Illinois 60680-5379

       Re: EXELON CORP
           Form 10-K for the Fiscal Year Ended December 31, 2019
           Filed February 11, 2020
           File No. 001-16169

Dear Mr. Souza:

       We have reviewed your filing 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.

Form 10-K for the Fiscal Year Ended December 31, 2019

Item 7. Management's Discussion and Analysis of Financial Condition and Results
of
Operations
FERC Order on the PJM MOPR, page 66

1.    You disclose that if Generation's state-supported nuclear plants in PJM
or NYISO are
      subjected to the Minimum Offer Price Rule (MOPR) without compensation
under an
      Fixed Resource Requirement (FRR) or similar program, it could have a
material adverse
      impact on Exelon's and Generation's financial statements. In this regard,
please tell us
      what consideration you gave to quantifying the expected impact of this
known uncertainty
      on your future results of operations. Refer to Item 303(a)(3)(ii) of
Regulation S-K.
 Fabian Souza
FirstNameCORP
EXELON LastNameFabian Souza
Comapany NameEXELON CORP
March 6, 2020
Page 2
March 6, 2020 Page 2
FirstName LastName




Critical Accounting Policies
Depreciable Lives of Property, Plant and Equipment (All Registrants), page 78

2.       We note from your disclosure on page 267 that you recorded significant
charges to
         earnings associated with accelerated depreciation due to early nuclear
plant retirements
         over the last three fiscal years. We also note your disclosure in
footnote 6 regarding the
         economic challenges faced by your nuclear generating stations and the
resulting potential
         for early retirement of the Dresden, Byron, and Braidwood nuclear
plants in Illinois. We
         also note that you have recorded charges to earnings over the last
three fiscal years
         associated with early nuclear plant retirements. Please tell us your
consideration of
         providing additional disclosures in your critical accounting policies
that allows for an
         assessment of the probability, magnitude and timing of future material
charges associated
         with accelerated deprecation or early retirement or shutdown of the
Dresden, Byron and
         Braidwood units, the net book value and revenues of the business units
along with a
         description of the specific events and/or changes in circumstances
that could reasonably
         be expected to result in accelerated deprecation or early retirement
or shutdown. Lastly,
         please address how the early retirement of these units would
necessitate any incremental
         charges associated with their asset retirement obligations. Refer to
Section V of SEC
         Release 33-8350 and Item 303(a)(3)(ii), which requires a description
of a known
         uncertainty that will have a material impact on income from continuing
operations.
Results of Operations by Registrant, page 84

3.       We note your presentation of the non-GAAP measure revenues net of
purchased power
         and fuel expense. Please present a reconciliation for this non-GAAP
measure in
         accordance with Item 10(e)(1)(i)(B) of Regulation S-K. In doing so,
reconcile this
         measures to the most directly comparable GAAP measure of gross margin.
If you do not
         believe gross margin that includes depreciation and amortization is
the most directly
         comparable GAAP measure, please tell us why in your response.
Item 8. Financial Statements and Supplementary Data
Note 18 -- Commitments and Contingencies
Asbestos Personal Injury Claims (Exelon and Generation), page 346

4.       We note your disclosure that it is reasonably possible that additional
exposure to estimated
         future asbestos-related bodily injury claims in excess of the amount
accrued could have a
         material, unfavorable impact on Exelon's and Generation's financial
statements. If it is at
         least reasonably possible that a loss exceeding amounts already
recognized may have been
         incurred and the amount of that additional loss would be material,
either disclose the
         estimated additional loss, or range of loss that is reasonably
possible, or state that such an
         estimate cannot be made. Refer to ASC 450-20-50-4.
 Fabian Souza
EXELON CORP
March 6, 2020
Page 3

        We remind you that the company and its management are responsible for
the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action
or absence of
action by the staff.

       You may contact Robert Babula, Staff Accountant at (202) 551-3339, or
Gus Rodriguez,
Branch Chief at (202) 551-3752 if you have questions regarding comments on the
financial
statements and related matters.



FirstName LastNameFabian Souza                            Sincerely,
Comapany NameEXELON CORP
                                                          Division of
Corporation Finance
March 6, 2020 Page 3                                      Office of Energy &
Transportation
FirstName LastName