SEC Comment Letter for NATIONAL HOUSING PARTNERSHIP REALTY FUND IV (CIK 0000780149) — May 26, 2005
NATIONAL HOUSING PARTNERSHIP REALTY FUND IV (CIK 0000780149)
Date: May 26, 2005 · CIK: 0000780149 · Accession: 0000000000-05-026051
AI Filing Summary & Sentiment
Letter
Mail Stop 4561 May 25, 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 IV Forms 10-KSB for the year ended December 31, 2004 File No. 0-15731
Dear Mr. Waters:
We have reviewed your May 10, 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. We do not understand how the Partnership`s ability to remove the general partner has significant effect on the success of the entity in light of your response to comment 1 that the general partner has operating control and financial control through various rights and has "demonstrated exercise of that control ... over the twenty- year history of the local limited partnerships." Please clarify as these conclusions appear inconsistent. In addition, please tell us how various rights and obligations held by the general partner documented in your response to prior comment 1 impacted your analysis under paragraph 5(b).
2. It is unclear from your response how you reached your conclusions under paragraph 5(c). Please explain why you believe substantially all the activities of the local limited partnerships do not involve and are not conducted on behalf of you and NHP, collectively. In addition, please tell us what other parties are involved in the activities and for whose benefit they are conducted.
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
May 25, 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 IV
Forms 10-KSB for the year ended December 31, 2004
File No. 0-15731
Dear Mr. Waters:
We have reviewed your May 10, 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. We do not understand how the Partnership`s ability to remove
the
general partner has significant effect on the success of the
entity
in light of your response to comment 1 that the general partner
has
operating control and financial control through various rights and
has "demonstrated exercise of that control ... over the twenty-
year
history of the local limited partnerships." Please clarify as
these
conclusions appear inconsistent. In addition, please tell us how
various rights and obligations held by the general partner
documented
in your response to prior comment 1 impacted your analysis under
paragraph 5(b).
2. It is unclear from your response how you reached your
conclusions
under paragraph 5(c). Please explain why you believe
substantially
all the activities of the local limited partnerships do not
involve
and are not conducted on behalf of you and NHP, collectively. In
addition, please tell us what other parties are involved in the
activities and for whose benefit they are conducted.
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 IV
May 25, 2005
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