SEC Comment Letter for HOUSING PROGRAMS LTD (CIK 0000750304) — Aug 1, 2005
HOUSING PROGRAMS LTD (CIK 0000750304)
Date: Aug. 1, 2005 · CIK: 0000750304 · Accession: 0000000000-05-039429
AI Filing Summary & Sentiment
File numbers found in text: 000-13808
Letter
Mail Stop 4561 VIA U.S. MAIL AND FAX (864) 239-5824 Mr. David R. Robertson President and Chief Executive Officer National Partnership Investments Corp. 55 Beattie Place, PO Box 1089 Greenville, SC 29602
Re: Housing Programs Limited Form 10-KSB for the year ended December 31, 2004 Filed April 8, 2005 File No. 000-13808
Dear Mr. Robertson:
We have reviewed your July 11, 2005 response letter and have the following additional comments.
1. We note that you considered factors in paragraph 17 in determining that you are not the primary beneficiary in any of the VIE`s. Please tell us how you first considered paragraph 16 in determining the entities in your related party group. In addition, please explain to us in sufficient detail how you considered and concluded on each of the indicators in paragraph 17 and your rationale for doing so. In your response, tell us how you weighted each of these factors in arriving at your conclusion.
* * * *
You may contact Josh Forgione, at (202) 551-3431, or me, at (202) 551-3403, if you have questions. Please respond to the comments included in this letter within 10 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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Show Raw Text
<DOCUMENT>
<TYPE>LETTER
<SEQUENCE>1
<FILENAME>filename1.txt
<TEXT>
August 1, 2005
Mail Stop 4561
VIA U.S. MAIL AND FAX (864) 239-5824
Mr. David R. Robertson
President and Chief Executive Officer
National Partnership Investments Corp.
55 Beattie Place, PO Box 1089
Greenville, SC 29602
Re: Housing Programs Limited
Form 10-KSB for the year ended December 31, 2004
Filed April 8, 2005
File No. 000-13808
Dear Mr. Robertson:
We have reviewed your July 11, 2005 response letter and have
the following additional comments.
1. We note that you considered factors in paragraph 17 in
determining
that you are not the primary beneficiary in any of the VIE`s.
Please
tell us how you first considered paragraph 16 in determining the
entities in your related party group. In addition, please explain
to
us in sufficient detail how you considered and concluded on each
of
the indicators in paragraph 17 and your rationale for doing so.
In
your response, tell us how you weighted each of these factors in
arriving at your conclusion.
* * * *
You may contact Josh Forgione, at (202) 551-3431, or me, at
(202) 551-3403, if you have questions. Please respond to the
comments
included in this letter within 10 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
??
??
??
??
</TEXT>
</DOCUMENT>