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SEC Company Response from CONSOLIDATED CAPITAL INSTITUTIONAL PROPERTIES (CIK 0000352983) — Jun 21, 2005

CONSOLIDATED CAPITAL INSTITUTIONAL PROPERTIES (CIK 0000352983)
Date: June 21, 2005 · CIK: 0000352983 · Accession: 0000711642-05-000273

AI Filing Summary & Sentiment

File numbers found in text: 000-10831

Referenced dates: June 14, 2005

Date
June 21, 2005
Author
/s/ Martha L. Long
Form
CORRESP
Company
CONSOLIDATED CAPITAL INSTITUTIONAL PROPERTIES (CIK 0000352983)

Letter

Re: Consolidated Capital Institutional Properties Item 4.02 Form 8-K filed May 26, 2005 File No. 000-10831

CONSOLIDATED CAPITAL INSTITUTIONAL PROPERTIES 55 Beattie Place, P.O. Box 1089 Greenville, SC 29602

June 21, 2005

Correspondence Filing Via Edgar and Overnight Delivery

United States Securities and Exchange Commission Division of Corporation Finance Mail Stop 4561 450 Fifth Street, NW Washington, D.C. 20549 Attn: Mr. Robert F. Telewicz, Jr.

Ladies and Gentlemen:

This letter responds to the comments of the staff of the Securities and Exchange Commission (the "Staff") addressed to Consolidated Capital Institutional Properties, a California limited partnership (the "Partnership"), in a letter dated June 14, 2005. The Partnership's response to the Staff's comments are set forth below and are numbered to correspond to the numbering of the Staff's comments in the Staff's letter.

* * * * *

Form 8-K

1. Comment: We note that you intend to file restated financial statements. However, you have not indicated when you intend to do so. Please tell us when you intend to file restated financial statements. We may have further comment after you file the restated financial statements.

Response: The Partnership intends to file restated financial statements in an amended Form 10-K/A by July 1, 2005.

2. Comment: Please tell us if your certifying officers have reconsidered the effect on the adequacy of your disclosure controls and procedures as of the end of the period covered by your Form 10-K for the period ended December 31, 2004 in light of the material error you have disclosed.

Response: The certifying officers of the Partnership's general partner have reevaluated the adequacy of the Partnership's disclosure controls and procedures in light of the material error that was disclosed. The certifying officers have improved the Partnership's disclosure controls and procedures that were in place for the period ended December 31, 2004 to ensure that transactions such as the transaction at issue are properly recorded at inception. Actions taken include improving the education of accounting personnel to ensure that all relevant personnel understand and apply the appropriate accounting treatment, as well as improving the Partnership's accounting review procedures. Such information will be disclosed in the Partnership's restated financial statements.

* * * * *

As requested by the Staff, the Partnership acknowledges that: (a) the Partnership is responsible for the adequacy and accuracy of the disclosure in its filings; (b) Staff comments or changes to disclosure in response to Staff comments in the filings reviewed by the Staff do not foreclose the Commission from taking any action with respect to the filing; and (c) the Partnership may not assert Staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.

If you have further questions regarding the information provided, please contact the undersigned or Stephen Waters. Mr. Waters can be reached directly at (864) 239-1554 or by fax at (864) 239-5824.

Sincerely,
/s/ Martha L. Long
Martha L. Long
Senior Vice President
ConCap Equities, Inc., the general
partner of Consolidated Capital
Institutional Properties

Show Raw Text
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<TEXT>
                CONSOLIDATED CAPITAL INSTITUTIONAL PROPERTIES
                         55 Beattie Place, P.O. Box 1089
                              Greenville, SC 29602

June 21, 2005

Correspondence Filing Via Edgar and Overnight Delivery

United States Securities and Exchange Commission
Division of Corporation Finance
Mail Stop 4561
450 Fifth Street, NW
Washington, D.C.  20549
Attn:  Mr. Robert F. Telewicz, Jr.

Re:   Consolidated Capital Institutional Properties
      Item 4.02 Form 8-K filed May 26, 2005
      File No. 000-10831

Ladies and Gentlemen:

This letter responds to the comments of the staff of the Securities and Exchange
Commission  (the  "Staff")  addressed  to  Consolidated  Capital   Institutional
Properties,  a California limited partnership (the  "Partnership"),  in a letter
dated June 14, 2005. The Partnership's  response to the Staff's comments are set
forth  below and are  numbered to  correspond  to the  numbering  of the Staff's
comments in the Staff's letter.

                        *     *     *     *     *

Form 8-K

1.   Comment:  We note that you intend to file  restated  financial  statements.
     However,  you have not  indicated  when you intend to do so. Please tell us
     when you intend to file restated financial statements.  We may have further
     comment after you file the restated financial statements.

      Response:    The Partnership intends to file restated financial
      statements in an amended Form 10-K/A by July 1, 2005.

2.   Comment:  Please tell us if your certifying  officers have reconsidered the
     effect on the adequacy of your disclosure controls and procedures as of the
     end of the period  covered by your Form 10-K for the period ended  December
     31, 2004 in light of the material error you have disclosed.

      Response:  The certifying  officers of the  Partnership's  general partner
      have reevaluated the adequacy of the Partnership's disclosure controls and
      procedures  in  light  of the  material  error  that  was  disclosed.  The
      certifying  officers have improved the Partnership's  disclosure  controls
      and  procedures  that were in place for the period ended December 31, 2004
      to ensure that  transactions such as the transaction at issue are properly
      recorded at inception.  Actions  taken include  improving the education of
      accounting  personnel to ensure that all relevant personnel understand and
      apply the  appropriate  accounting  treatment,  as well as  improving  the
      Partnership's  accounting  review  procedures.  Such  information  will be
      disclosed in the Partnership's restated financial statements.

                        *     *     *     *     *

As  requested  by  the  Staff,  the  Partnership   acknowledges  that:  (a)  the
Partnership  is  responsible  for the adequacy and accuracy of the disclosure in
its filings;  (b) Staff  comments or changes to  disclosure in response to Staff
comments in the filings  reviewed by the Staff do not foreclose  the  Commission
from taking any action with respect to the filing;  and (c) the  Partnership may
not assert  Staff  comments  as a defense  in any  proceeding  initiated  by the
Commission or any person under the federal securities laws of the United States.

If you have further questions regarding the information provided, please contact
the undersigned or Stephen Waters.  Mr. Waters can be reached  directly at (864)
239-1554 or by fax at (864) 239-5824.

                                   Sincerely,

                                    /s/ Martha L. Long
                                    Martha L. Long
                                    Senior Vice President
                                    ConCap Equities, Inc., the general
                                    partner of Consolidated Capital
                                    Institutional Properties

</TEXT>
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