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[LTC LETTERHEAD]

October 26,
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 21, 2005 on the
above-referenced filing.

SEC Comment in letter dated October 21, 2005:

1.             We read your response to comment
1.  Please summarize the efforts you have
made to obtain access to the financial statements or any other financial
information for Alterra.

Company’s Response to #1:

Pursuant
to the provisions of our master leases with Alterra, we are entitled to, and do
receive, certain operating information related to the properties we have under
lease with Alterra and certain operating information of Alterra not including
balance sheet or cash flow information.  Accordingly,
such information does not include sufficient information to provide summarized
financial information under Rule 1-02(bb) of Regulation S-X.  Provisions of the master leases do not
expressly grant us permission to publish Alterra’s financial information in any
of our public filings.  In providing us
with certain operating information, Alterra’s expectations are that we will treat
this information confidentially.  Therefore,
to date, our efforts to obtain access to financial statements or any other
financial information for Alterra have been limited by our contractual obligations
under lease agreements with Alterra and we have not approached Alterra, nor do
we currently expect Alterra to provide such summarized financial information.

We
understand that Alterra has merged with Brookdale Senior Living, Inc. and Brookdale
Senior Living, Inc. has recently filed a registration statement with the
Commission (File No. 333-127372).  Should
Brookdale Senior Living, Inc. become a reporting company subject to the
filing requirements of the Commission, we will include their summarized
financial data in our filings with the Commission in the same manner as we do
for our other lessees, guarantors and obligators that meet the “significant
subsidiary” definition of Rule 1-02.

  Very truly yours,

  LTC PROPERTIES,
  INC.

  /s/ Wendy L. Simpson

  Wendy L. Simpson

  Vice Chairman, Chief Financial Officer and Treasurer