SEC Comment Letter for UNIPROP MANUFACTURED HOUSING COMMUNITIES INCOME FUND (CIK 0000769856) — Apr 25, 2005
UNIPROP MANUFACTURED HOUSING COMMUNITIES INCOME FUND (CIK 0000769856)
Date: April 25, 2005 · CIK: 0000769856 · Accession: 0000000000-05-020022
AI Filing Summary & Sentiment
Letter
Mail Stop 0409 VIA U.S. MAIL AND FAX (248) 645-2154 Joel Schwartz Chief Financial Officer Uniprop Manufactured Housing Communities Income Fund 280 Daines Street Birmingham, MI 48009
Re: Uniprop Manufactured Housing Communities Income Fund Form 10-K for the year ended December 31, 2004 File No. 0-15940
Dear Mr. Schwartz:
We have reviewed the above referenced filing and have the following comment. We have limited our review to only your financial statements and related disclosures and will make no further review of your documents. As such, all persons who are responsible for the adequacy and accuracy of the disclosure are urged to be certain that they have included all information required pursuant to the Securities Exchange Act of 1934. Where indicated, we think you should revise your documents in response to this comment. If you disagree, we will consider your explanation as to why our comment is inapplicable or a revision is unnecessary. Please be as detailed as necessary in your explanation. After reviewing this information, we may or may not raise 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 comment or on any other aspect of our review. Feel free to call us at the telephone numbers listed at the end of this letter.
Form 10-K for the Year Ended December 31, 2004
1. We note that the certification filed as Exhibit 31.1 to your Form 10-K was not in the proper form. The required certification must be in the exact form prescribed; the wording of the required certification may not be changed in any respect. Certain portions of the certification relating to internal control over financial reporting may be omitted as stated in Section III.E. of SEC Release No. 33-8238. Accordingly, please file an amendment to your Form 10-K that includes the entire filing together with the certification of your current CEO/CFO in the form currently set forth in Item 601(b)(31) of Regulation S-K.
* * * *
We urge all persons who are responsible for the accuracy and adequacy of the disclosure in the filing reviewed by the staff to be certain that they have provided all information investors require for an informed decision. Since the company and its management are in possession of all facts relating to a company`s disclosure, they are responsible for the accuracy and adequacy of the disclosures they have made.
In connection with responding to our comments, please provide, in writing, a statement from the company acknowledging that:
* the company is responsible for the adequacy and accuracy of the disclosure in the filing;
* staff comments or changes to disclosure in response to staff comments do not foreclose the Commission from taking any action with respect to the filing; and
* the company 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.
In addition, please be advised that the Division of Enforcement has access to all information you provide to the staff of the Division of Corporation Finance in our review of your filing or in response to our comments on your filing.
As appropriate, please respond to these comments within 10 business days or tell us when you will provide us with a response. Please furnish a cover letter with your amendment that keys your responses to our comments and provides any requested supplemental information. Detailed cover letters greatly facilitate our review. Please file your cover letter on EDGAR. Please understand that we may have additional comments after reviewing your responses to our comments.
You may contact James Webster, Staff Accountant, at (202) 824- 5574 or me, at (202) 942-2813 if you have questions.
Sincerely,
Daniel Gordon
Accounting Branch Chief
Show Raw Text
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<TEXT>
April 25, 2005
Mail Stop 0409
VIA U.S. MAIL AND FAX (248) 645-2154
Joel Schwartz
Chief Financial Officer
Uniprop Manufactured Housing Communities Income Fund
280 Daines Street
Birmingham, MI 48009
Re: Uniprop Manufactured Housing Communities Income Fund
Form 10-K for the year ended December 31, 2004
File No. 0-15940
Dear Mr. Schwartz:
We have reviewed the above referenced filing and have the
following comment. We have limited our review to only your
financial
statements and related disclosures and will make no further review
of
your documents. As such, all persons who are responsible for the
adequacy and accuracy of the disclosure are urged to be certain
that
they have included all information required pursuant to the
Securities Exchange Act of 1934. Where indicated, we think you
should revise your documents in response to this comment. If you
disagree, we will consider your explanation as to why our comment
is
inapplicable or a revision is unnecessary. Please be as detailed
as
necessary in your explanation. After reviewing this information,
we
may or may not raise 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 comment or on any other
aspect
of our review. Feel free to call us at the telephone numbers
listed
at the end of this letter.
Form 10-K for the Year Ended December 31, 2004
1. We note that the certification filed as Exhibit 31.1 to your
Form
10-K was not in the proper form. The required certification must
be
in the exact form prescribed; the wording of the required
certification may not be changed in any respect. Certain portions
of
the certification relating to internal control over financial
reporting may be omitted as stated in Section III.E. of SEC
Release
No. 33-8238. Accordingly, please file an amendment to your Form
10-K
that includes the entire filing together with the certification of
your current CEO/CFO in the form currently set forth in Item
601(b)(31) of Regulation S-K.
* * * *
We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filing reviewed by the staff to
be
certain that they have provided all information investors require
for
an informed decision. Since the company and its management are in
possession of all facts relating to a company`s disclosure, they
are
responsible for the accuracy and adequacy of the disclosures they
have made.
In connection with responding to our comments, please
provide,
in writing, a statement from the company acknowledging that:
* the company is responsible for the adequacy and accuracy of the
disclosure in the filing;
* staff comments or changes to disclosure in response to staff
comments do not foreclose the Commission from taking any action
with
respect to the filing; and
* the company 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.
In addition, please be advised that the Division of Enforcement
has
access to all information you provide to the staff of the Division
of
Corporation Finance in our review of your filing or in response to
our comments on your filing.
As appropriate, please respond to these comments within 10
business days or tell us when you will provide us with a response.
Please furnish a cover letter with your amendment that keys your
responses to our comments and provides any requested supplemental
information. Detailed cover letters greatly facilitate our
review.
Please file your cover letter on EDGAR. Please understand that we
may have additional comments after reviewing your responses to our
comments.
You may contact James Webster, Staff Accountant, at (202)
824-
5574 or me, at (202) 942-2813 if you have questions.
Sincerely,
Daniel Gordon
Accounting Branch Chief
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Uniprop Manufactured Housing Communities Income Fund
April 25, 2005
3
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