SEC Comment Letter for CBL & ASSOCIATES PROPERTIES INC (CBL) (CIK 0000910612) (CBL) — Nov 21, 2006
CBL & ASSOCIATES PROPERTIES INC (CBL) (CIK 0000910612)
Date: Nov. 21, 2006 · CIK: 0000910612 · Accession: 0000000000-06-057244
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 001-12494
Referenced dates: October 12, 2006
Letter
Mail Stop 4561 November 20, 2006 Charles B. Lebovitz 2030 Hamilton Place Blvd, Suite 500 Chattanooga, TN 37421
Re: CBL & Associates Properties, Inc. Form 10-K for Fiscal Ye ar Ended December 31, 2005 Filed March 15, 2006 Forms 10-Q for Fiscal Quarters E nded March 31, 200 6 and June 30, File No. 001-12494
Dear Mr. Lebovitz:
We have reviewed your response letter dated October 12, 2006, and have the following additional comments.
Form 10-K
Management’s Discussion and Analysis of Fi nancial Condition and Results of Operations
Funds From Operations, page 56 1. We have read and considered your response to comment two. Given the adjustments you make to FFO, tell us what consideration you have given to including the disclosure items noted in question 8 of the Frequently Asked Questions Regarding the Use of Non-GAAP Financial Measures. Additionally, explain to us how you determined your calculation of FFO from continuing operations was appropriate and why th e amount calculated by you would differ from FFO inclusive of minority intere st, less preferred dividends.
Exhibits 32.1 and 32.2 2. We have read and considered your response to comment four. We will continue to monitor your filing for your amended Form 10-K for the year ended December 31, 2005. * * * *
As appropriate, please respond to these co mments within 10 business days or tell us when you will provide us with a response. Detailed cover letters gr eatly facilitate our
Charles B. Lebovitz CBL & Associates Properties, Inc. November 20, 2006 Page 2 review. Please file your cover letter on E DGAR. Please understa nd that we may have additional comments after reviewin g your responses to our comments.
You may contact Yolanda Crittendon, Sta ff Accountant, at (202) 551-3472 or the undersigned at (202) 551-3438 if you have questions.
Sincerely,
Robert Telewicz
Senior Staff Accountant
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Mail Stop 4561 November 20, 2006 Charles B. Lebovitz 2030 Hamilton Place Blvd, Suite 500 Chattanooga, TN 37421 Re: CBL & Associates Properties, Inc. Form 10-K for Fiscal Ye ar Ended December 31, 2005 Filed March 15, 2006 Forms 10-Q for Fiscal Quarters E nded March 31, 200 6 and June 30, 2006 File No. 001-12494 Dear Mr. Lebovitz: We have reviewed your response letter dated October 12, 2006, and have the following additional comments. Form 10-K Management’s Discussion and Analysis of Fi nancial Condition and Results of Operations Funds From Operations, page 56 1. We have read and considered your response to comment two. Given the adjustments you make to FFO, tell us what consideration you have given to including the disclosure items noted in question 8 of the Frequently Asked Questions Regarding the Use of Non-GAAP Financial Measures. Additionally, explain to us how you determined your calculation of FFO from continuing operations was appropriate and why th e amount calculated by you would differ from FFO inclusive of minority intere st, less preferred dividends. Exhibits 32.1 and 32.2 2. We have read and considered your response to comment four. We will continue to monitor your filing for your amended Form 10-K for the year ended December 31, 2005. * * * * As appropriate, please respond to these co mments within 10 business days or tell us when you will provide us with a response. Detailed cover letters gr eatly facilitate our Charles B. Lebovitz CBL & Associates Properties, Inc. November 20, 2006 Page 2 review. Please file your cover letter on E DGAR. Please understa nd that we may have additional comments after reviewin g your responses to our comments. You may contact Yolanda Crittendon, Sta ff Accountant, at (202) 551-3472 or the undersigned at (202) 551-3438 if you have questions. Sincerely, Robert Telewicz Senior Staff Accountant