SEC Comment Letter for NATIONAL HOUSING PARTNERSHIP REALTY FUND I (CIK 0000731131) — Jun 14, 2005
NATIONAL HOUSING PARTNERSHIP REALTY FUND I (CIK 0000731131)
Date: June 14, 2005 · CIK: 0000731131 · Accession: 0000000000-05-029804
AI Filing Summary & Sentiment
Letter
Mail Stop 4561 June 15, 2005 VIA U.S. MAIL AND FAX (864) 239-5824 Mr. Stephen Waters Vice President National Corporation for Housing Partnerships 55 Beattie Place, PO Box 1089 Greenville, SC 29602
Re: National Housing Partnership Realty Fund I Form 10-KSB for the year ended December 31, 2004 File No. 0-13465
Dear Mr. Waters:
We have reviewed your June 9, 2005 response letter and have the following additional comments. Please understand that the purpose of our review process is to assist you in your compliance with the applicable disclosure requirements and to enhance the overall disclosure in your filing. We look forward to working with you in these respects. We welcome any questions you may have about our comments or any other aspect of our review. Feel free to call us at the telephone numbers listed at the end of this letter.
Form 10-KSB for the year ended December 31, 2004
Financial Statements and Notes
Note 1 - Summary of Partnership Organization and Significant Accounting Policies
Recent Accounting Pronouncements
1. Considering the disproportionate voting rights of the Partnership and your response to our May 25, 2005 comment 2 stating the Partnership has not identified parties other than the Partnership and NHP, a related party, involved in the activities of the local limited partnerships, and for whom these activities are conducted, it appears you have met the criteria in paragraph 5(c). Please explain how you have concluded that the local limited partnerships are not VIEs under paragraph 5(c) as stated in your response to our April 13, 2005 comment 2 in light of these facts.
2. Given the related party relationship of the Partnership and the general partner of the local limited partnerships, please explain the substance of the Partnership`s ability to remove the general partner without cause. Please provide the relevant terms of the partnership agreements, as applicable.
You may contact Matthew Dowling, Staff Accountant, at (202) 551-3467 or me at (202) 551-3403 if you have questions. Please respond to the comments included in this letter within ten business days or tell us when you will provide us with a response. Please file your response on EDGAR.
Sincerely,
Steven Jacobs
Accounting Branch Chief
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<DOCUMENT>
<TYPE>LETTER
<SEQUENCE>1
<FILENAME>filename1.txt
<TEXT>
Mail Stop 4561
June 15, 2005
VIA U.S. MAIL AND FAX (864) 239-5824
Mr. Stephen Waters
Vice President
National Corporation for Housing Partnerships
55 Beattie Place, PO Box 1089
Greenville, SC 29602
Re: National Housing Partnership Realty Fund I
Form 10-KSB for the year ended December 31, 2004
File No. 0-13465
Dear Mr. Waters:
We have reviewed your June 9, 2005 response letter and have
the
following additional comments. Please understand that the purpose
of
our review process is to assist you in your compliance with the
applicable disclosure requirements and to enhance the overall
disclosure in your filing. We look forward to working with you in
these respects. We welcome any questions you may have about our
comments or any other aspect of our review. Feel free to call us
at
the telephone numbers listed at the end of this letter.
Form 10-KSB for the year ended December 31, 2004
Financial Statements and Notes
Note 1 - Summary of Partnership Organization and Significant
Accounting Policies
Recent Accounting Pronouncements
1. Considering the disproportionate voting rights of the
Partnership
and your response to our May 25, 2005 comment 2 stating the
Partnership has not identified parties other than the Partnership
and
NHP, a related party, involved in the activities of the local
limited
partnerships, and for whom these activities are conducted, it
appears
you have met the criteria in paragraph 5(c). Please explain how
you
have concluded that the local limited partnerships are not VIEs
under
paragraph 5(c) as stated in your response to our April 13, 2005
comment 2 in light of these facts.
2. Given the related party relationship of the Partnership and the
general partner of the local limited partnerships, please explain
the
substance of the Partnership`s ability to remove the general
partner
without cause. Please provide the relevant terms of the
partnership
agreements, as applicable.
You may contact Matthew Dowling, Staff Accountant, at (202)
551-3467 or me at (202) 551-3403 if you have questions. Please
respond to the comments included in this letter within ten
business
days or tell us when you will provide us with a response. Please
file your response on EDGAR.
Sincerely,
Steven Jacobs
Accounting Branch Chief
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Mr. Stephen Waters
National Housing Partnership Realty Fund I
June 15, 2005
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