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SEC Comment Letter for RAMCO GERSHENSON PROPERTIES TRUST (CIK 0000842183) — Apr 18, 2005

RAMCO GERSHENSON PROPERTIES TRUST (CIK 0000842183)
Date: April 18, 2005 · CIK: 0000842183 · Accession: 0000000000-05-018858

AI Filing Summary & Sentiment

Date
April 18, 2005
Author
Thomas Flinn
Form
UPLOAD
Company
RAMCO GERSHENSON PROPERTIES TRUST (CIK 0000842183)

Letter

April 18, 2005 Mail Stop 0409 via U.S. Mail and Fax (248) 592-6201 Mr. Richard J. Smith Chief Financial Officer Ramco-Gershenson Properties Trust 31500 Northwestern Highway, Suite 300 Farmington Hill, Michigan 48334

RE: Ramco-Gershenson Properties Trust Form 8-K filed April 15, 2005 File No. 1-10093

Dear Mr. Smith:

We have reviewed your filing and have the following comments. Where indicated, we think you should revise your document in response to these comments. 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. In some of our comments, we may ask you to provide us with supplemental information so we may better understand your disclosure. 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 comments or on any other aspect of our review. Feel free to call me at the telephone number listed at the end of this letter.

1. Revise to provide the information required by Item 304(a)(1)(v) of Regulation S-K, regarding your ineffective internal controls noted by your predecessor accountants.

File an amendment under cover of Form 8-K/A and include the ITEM 4.01 designation, including the letter from the former accountant filed as an Exhibit 16. Please note that your former accountants should make it clear within the Exhibit 16 letter that it is in reference to your amended Form 8-K.

We urge all persons who are responsible for the accuracy and adequacy of the disclosure in the filings reviewed by the staff to be certain that they have provided all information investors require. 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 filings; * staff comments or changes to disclosure in response to staff comments in the filings reviewed by the staff 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.

Please provide the supplemental information requested above within business days from the date of this letter. The supplemental information should be filed as correspondence on EDGAR. The amendment requested should be filed as promptly as possible and should be reviewed by the former accountants. The letter required by Exhibit 16 should cover any revised disclosures.

Any questions regarding the above should be directed to me at (202) 824-5225.

Sincerely,
Thomas Flinn
Staff Accountant

Show Raw Text
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<TEXT>

      April 18, 2005

Mail Stop 0409 via U.S. Mail and Fax (248) 592-6201

Mr. Richard J. Smith
Chief Financial Officer
Ramco-Gershenson Properties Trust
31500 Northwestern Highway, Suite 300
Farmington Hill, Michigan 48334

RE:	Ramco-Gershenson Properties Trust
	Form 8-K filed April 15, 2005
            File No. 1-10093

Dear Mr. Smith:

We have reviewed your filing and have the following comments.
Where
indicated, we think you should revise your document in response to
these comments.  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.  In some
of
our comments, we may ask you to provide us with supplemental
information so we may better understand your disclosure.  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 comments or on any other
aspect
of our review.  Feel free to call me at the telephone number
listed
at the end of this letter.

1. Revise to provide the information required by Item 304(a)(1)(v)
of
Regulation S-K, regarding your ineffective internal controls noted
by
your predecessor accountants.

File an amendment under cover of Form 8-K/A and include the ITEM
4.01
designation, including the letter from the former accountant filed
as
an Exhibit 16.  Please note that your former accountants should
make
it clear within the Exhibit 16 letter that it is in reference to
your
amended Form 8-K.

We urge all persons who are responsible for the accuracy and
adequacy
of the disclosure in the filings reviewed by the staff to be
certain
that they have provided all information investors require.  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 filings;
* staff comments or changes to disclosure in response to staff
comments in the filings reviewed by the staff 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.

Please provide the supplemental information requested above within
10
business days from the date of this letter.  The supplemental
information should be filed as correspondence on EDGAR.  The
amendment requested should be filed as promptly as possible and
should be reviewed by the former accountants.  The letter required
by
Exhibit 16 should cover any revised disclosures.

Any questions regarding the above should be directed to me at
(202)
824-5225.

						Sincerely,

						Thomas Flinn
						Staff Accountant

Ramco-Gershenson Properties Trust
April 18, 2005

Page 2

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</DOCUMENT>