SEC Comment Letter for RAMCO GERSHENSON PROPERTIES TRUST (CIK 0000842183) — May 18, 2005
RAMCO GERSHENSON PROPERTIES TRUST (CIK 0000842183)
Date: May 18, 2005 · CIK: 0000842183 · Accession: 0000000000-05-024531
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May 18, 2005
Mail Stop 4561 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 May 11, 2005
File No. 1-10093
Dear Mr. Smith:
We have reviewed your filing and have the following comments. 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. Please supplementally explain how the audit committee concluded
that Grant Thornton met the independence requirements of Rules 2-
01(b) and (c) of Regulation S-X. In addition, please
supplementally
explain the nature and extent of the services Grant Thornton
provided
to the company regarding the documentation and testing of internal
controls. Your response should address, but not be limited to,
the
following:
* The dates that Grant Thornton started and completed its services
* The specific services Grant Thornton provided and which internal
controls that Grant Thornton documented and tested
*
Whether Grant Thornton performed any services related to the
material
weakness identified by the company which led to the restatement of
the company`s financial statements, and if so, the details
regarding
any such services performed
* Whether Grant Thornton performed any services related to the
remediation of any internal control deficiency or weakness, and if
so, the nature and timing of the remediation efforts Grant
Thornton
provided
* Whether Grant Thornton provided any services or had any
involvement
(direct or indirect) in reporting to the Audit Committee regarding
internal controls, and if so, the dates of Grant`s services or
involvement
2. Please supplementally explain the nature of each of the
accounting
matters you discussed with Grant Thornton, although none applied
to
any specific transaction.
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
five business days from the date of this letter. The supplemental
information should be filed as correspondence on EDGAR.
Any questions regarding the above should be directed to me at
(202)
551-3469.
Sincerely,
Thomas Flinn
Staff Accountant
Ramco-Gershenson Properties Trust
May 18, 2005
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