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[LTC LETTERHEAD]

October 14,
2005

Steven Jacobs

Accounting Branch Chief

Securities and Exchange
Commission

Division of Corporate
Finance

Washington DC, 20549

Re:                             LTC
Properties, Inc.

Form 10-K for the year ended December 31, 2004

Filed February 28, 2005

File No. 001-11314

Dear Mr. Jacobs:

We have the following
response to your comment letter dated October 11, 2005 on the
above-referenced filing.

FORM 10-K

Financial Statements and Notes

Note 3.  Major Operators, page 54

SEC Comment:

1.             Please tell us how you evaluated your asset
concentration level to determine the financial information required for Alterra related to properties
subject to net lease.  In determining
whether asset concentration thresholds are crossed, aggregate net lease
properties and mortgage loans to the same lessee or guarantor, obligor, or
group of related lessees or obligors, or loans on related properties.  Properties are related, for example, if they
are subject to cross default collateralization agreements.  At concentration levels over 20% of total
assets please include audited financial statements of the
lessee/guarantor/obligor.  If the
lessee/guarantor/obligor is a public company currently filing reports with the
Commission, only summarized data
(Rule 1-02(bb) of Regulation S-X and FAS 95 cash flow information) need be
provided.  At concentration levels
between 10-20%, only summarized data need be provided.

Company’s Response to #1:

In evaluating our asset
concentration levels we look at aggregate net lease properties and mortgage
loans related to the same lessee, guarantor, obligor or group of related
leases, obligors or loans on related properties.  We consider cross default collateralization
agreements in grouping related leases, obligors and/or loans.  At December 31, 2004, Alterra leased 35
assisted living properties from us under four master leases.  In determining our concentration level with
Alterra, we combined the assets under the four master leases we have with them
to determine that 12.6% of our total assets at December 31, 2004 were
concentrated with Alterra.  At December 31,
2004 we had no mortgage loans to Alterra or loans on any Alterra related property.  Since Alterra is not a publicly traded
company we do not have access to their financial statements and thus are not
able to provide summarized financial data for Alterra.

The following statements
are being provided at the request of the Securities and Exchange Commission as
outlined in its letter dated October 11, 2005:

•                                          LTC
Properties, Inc. is responsible for the adequacy and accuracy of the
disclosure in its filings with the Securities and Exchange Commission;

•                                          staff
comments or changes to disclosure in response to staff comments do not
foreclose the Commission from taking any action with respect to the filings;
and

•                                          LTC
Properties, Inc. 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.

  Very truly yours,

  LTC PROPERTIES,
  INC.

  /s/ Wendy Simpson

  Wendy L. Simpson

  Vice Chairman, Chief Financial Officer and Treasurer