SEC Comment Letter for COUSINS PROPERTIES INC (CUZ) (CIK 0000025232) (CUZ) — Jul 17, 2006
COUSINS PROPERTIES INC (CUZ) (CIK 0000025232)
Date: July 17, 2006 · CIK: 0000025232 · Accession: 0000000000-06-033121
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 001-11312
Referenced dates: May 19, 2006
Letter
Mail Stop 4561 July 17, 2006 James A. Fleming 2500 Windy Ridge Parkway, Suite 1600 Atlanta, GA 30339
Re: Cousins Properties Incorporated Form 10-K for Fiscal Ye ar Ended December 31, 2005 Filed March 14, 2006 File No. 001-11312
Dear Mr. Fleming:
We have reviewed your response letter dated May 19, 2006 and have the following additional comments.
Form 10-K
Management’s Discussion and Analysis of Fi nancial Condition and Results of Operations
Liquidity and Capital Resources
Cash Flows, page 45 1. We have read and considered your respons e to comment one. When distributions have been or are expected to be in exce ss of cash flows from ope rating activities, the company should identify the alternative source of the excess distributions. In future filings, this disclosure should be made both when discus sing historical distributions, as well as, when the company is discu ssing the expected source of future distributions. Advise us if you plan to expand your disclosures in future filings. Off Balance Sheet Arrangements, page 47 2. We have read and considered your response to comment two. It appears that the loan guarantees relating to The Georgian project and CL Ashton may not be subject to the initial recognition and initial measurement provisions of paragraph 7 (f) of FIN 45. However, it remains unclear of how the company complies with the disclosure requirements of paragraphs 13 – 16 of FIN 45. Please advise.
James A. Fleming Cousins Properties Incorporated July 17, 2006 Page 2 Note 1 – Significant Accounting Policies
Multi-Family Residential Sales, page F-12 3. We have read and considered your response to comment three. We noted that you do not believe that the continui ng involvement criteria set fort h in paragraph 12 of SFAS 66 applies to your evaluation of continuing investment as it ad dresses situations where there are contractually required paym ents by the buyer on its debt. Explain to us your assessment of the collectibility of the sales price demonstrated by the buyer’s commitment to pay.
* * * *
As appropriate, please respond to these co mments within 10 business days or tell us when you will provide us with a response. Detailed cover letters gr eatly facilitate our review. Please file your cover letter on E DGAR. Please understa nd that we may have additional comments after reviewing your responses to our comments.
You may contact Yolanda Crittendon, Sta ff Accountant, at (202) 551-3472 or the undersigned at (202) 551-3498 if you have questions.
S i n c e r e l y ,
Linda VanDoorn Senior Assistant Chief Accountant
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Mail Stop 4561
July 17, 2006
James A. Fleming
2500 Windy Ridge Parkway, Suite 1600
Atlanta, GA 30339
Re: Cousins Properties Incorporated
Form 10-K for Fiscal Ye ar Ended December 31, 2005
Filed March 14, 2006
File No. 001-11312
Dear Mr. Fleming:
We have reviewed your response letter dated May 19, 2006 and have the
following additional comments.
Form 10-K
Management’s Discussion and Analysis of Fi nancial Condition and Results of Operations
Liquidity and Capital Resources
Cash Flows, page 45
1. We have read and considered your respons e to comment one. When distributions
have been or are expected to be in exce ss of cash flows from ope rating activities, the
company should identify the alternative source of the excess distributions. In future
filings, this disclosure should be made both when discus sing historical distributions,
as well as, when the company is discu ssing the expected source of future
distributions. Advise us if you plan to expand your disclosures in future filings.
Off Balance Sheet Arrangements, page 47
2. We have read and considered your response to comment two. It appears that the loan
guarantees relating to The Georgian project and CL Ashton may not be subject to the
initial recognition and initial measurement provisions of paragraph 7 (f) of FIN 45.
However, it remains unclear of how the company complies with the disclosure
requirements of paragraphs 13 – 16 of FIN 45. Please advise.
James A. Fleming
Cousins Properties Incorporated
July 17, 2006 Page 2
Note 1 – Significant Accounting Policies
Multi-Family Residential Sales, page F-12
3. We have read and considered your response to comment three. We noted that you do
not believe that the continui ng involvement criteria set fort h in paragraph 12 of SFAS
66 applies to your evaluation of continuing investment as it ad dresses situations
where there are contractually required paym ents by the buyer on its debt. Explain to
us your assessment of the collectibility of the sales price demonstrated by the buyer’s commitment to pay.
* * * *
As appropriate, please respond to these co mments within 10 business days or tell
us when you will provide us with a response. Detailed cover letters gr eatly facilitate our
review. Please file your cover letter on E DGAR. Please understa nd that we may have
additional comments after reviewing your responses to our comments.
You may contact Yolanda Crittendon, Sta ff Accountant, at (202) 551-3472 or the
undersigned at (202) 551-3498 if you have questions.
S i n c e r e l y ,
Linda VanDoorn
Senior Assistant Chief Accountant