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SEC Comment Letter for NATIONAL HOUSING PARTNERSHIP REALTY FUND TWO (CIK 0000762859) — Aug 1, 2005

NATIONAL HOUSING PARTNERSHIP REALTY FUND TWO (CIK 0000762859)
Date: Aug. 1, 2005 · CIK: 0000762859 · Accession: 0000000000-05-039409

AI Filing Summary & Sentiment

File numbers found in text: 000-14458

Date
August 1, 2005
Author
Steven Jacobs
Form
UPLOAD
Company
NATIONAL HOUSING PARTNERSHIP REALTY FUND TWO (CIK 0000762859)

Letter

Mail Stop 4561 VIA U.S. MAIL AND FAX (864) 239-5824 Mr. David R. Robertson President and Chief Executive Officer National Corporation for Housing Partnerships 55 Beattie Place, PO Box 1089 Greenville, SC 29602

Re: National Housing Partnership Realty Fund Two Form 10-KSB for the year ended December 31, 2004 Filed March 30, 2005 File No. 000-14458

Dear Mr. Robertson:

We have reviewed your July 14, 2005 response letter and have the following additional comments.

1. We note your conclusion that the general partner is more closely associated with the local limited partnership and therefore is the primary beneficiary. 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

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 Corporation for Housing Partnerships
55 Beattie Place, PO Box 1089
Greenville, SC 29602

Re:	National Housing Partnership Realty Fund Two
      Form 10-KSB for the year ended December 31, 2004
      Filed March 30, 2005
      File No. 000-14458

Dear Mr. Robertson:

      We have reviewed your July 14, 2005 response letter and have
the following additional comments.

1. We note your conclusion that the general partner is more
closely
associated with the local limited partnership and therefore is the
primary beneficiary.  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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</TEXT>
</DOCUMENT>