SEC Comment Letter for CBL & ASSOCIATES PROPERTIES INC (CBL) (CIK 0000910612) (CBL) — May 24, 2012
CBL & ASSOCIATES PROPERTIES INC (CBL) (CIK 0000910612)
Date: May 24, 2012 · CIK: 0000910612 · Accession: 0000000000-12-027093
AI Filing Summary & Sentiment
Reasoning
Referenced dates: April 19, 2012
Letter
UNITED STATES SECURITIES AND EXCHANGE COMMISSION WASHINGTON, D.C. 20549 DIVISION OF CORPORATION FINANCE May 24, 2012 Via e-mail Mr. Stephen D. Lebovitz President and Chief Executive Officer CBL & Associates Properties, Inc. 2030 Hamilton Place Blvd., Suite 500 Chattanooga, TN 37421 RE: CBL & Associates Properties, Inc. Form 10-K for the Fiscal Year Ended December 31, 2011 Filed February 29, 2012 File No. 1-12494
Dear Mr. Lebovitz: We have reviewed your response letter dated April 19, 2012 and have the following additional comment. In our comment, we ask yo u to provide us with information so we may better understand your disclosure. Please respond to this letter via EDGAR within ten business days by providing the requested information or by advising us when you will provide the requested response. After reviewing any amendment to your f ilings and the information you provide in response to this comment, we may have additional comments. Results of Operations
Operational Review, page 50
1. We note your response to our prior comment 8 and reissue that comment in part. In future Exchange Act periodic reports, please expand your discussion of leasing results to include in such disclosure a discussion of tenant improveme nt costs, leasing commissions and tenant concessions. Please provide such disclosure on a squa re footage basis.
We urge all persons who are responsible for th e accuracy and adequacy of the disclosure in the filing to be certain that the filing include s the information the Securities Exchange Act of 1934 and all applicable Exchange Act rules requir e. 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.
Mr. Stephen D. Lebovitz CBL & Associates Properties, Inc. May 24, 2012 Page 2 You may contact William Demarest, Staff Accountant, at (202) 551-3432 with any questions on the financial statements or relate d matters. Please cont act Jerard Gibson, Staff Attorney at (202) 551-3473 or me at (202) 551-3655 with any other questions. S i n c e r e l y , / s / S o n i a B a r r o s S o n i a B a r r o s S p e c i a l C o u n s e l
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UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549
DIVISION OF
CORPORATION FINANCE
May 24, 2012
Via e-mail
Mr. Stephen D. Lebovitz President and Chief Executive Officer CBL & Associates Properties, Inc. 2030 Hamilton Place Blvd., Suite 500 Chattanooga, TN 37421 RE: CBL & Associates Properties, Inc.
Form 10-K for the Fiscal Year Ended December 31, 2011
Filed February 29, 2012 File No. 1-12494
Dear Mr. Lebovitz:
We have reviewed your response letter dated April 19, 2012 and have the following
additional comment. In our comment, we ask yo u to provide us with information so we may
better understand your disclosure.
Please respond to this letter via EDGAR within ten business days by providing the
requested information or by advising us when you will provide the requested response.
After reviewing any amendment to your f ilings and the information you provide in
response to this comment, we may have additional comments. Results of Operations
Operational Review, page 50
1. We note your response to our prior comment 8 and reissue that comment in part. In
future Exchange Act periodic reports, please expand your discussion of leasing results to
include in such disclosure a discussion of tenant improveme nt costs, leasing commissions
and tenant concessions. Please provide such disclosure on a squa re footage basis.
We urge all persons who are responsible for th e accuracy and adequacy of the disclosure
in the filing to be certain that the filing include s the information the Securities Exchange Act of
1934 and all applicable Exchange Act rules requir e. 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.
Mr. Stephen D. Lebovitz
CBL & Associates Properties, Inc. May 24, 2012 Page 2
You may contact William Demarest, Staff Accountant, at (202) 551-3432 with any
questions on the financial statements or relate d matters. Please cont act Jerard Gibson, Staff
Attorney at (202) 551-3473 or me at (202) 551-3655 with any other questions.
S i n c e r e l y , / s / S o n i a B a r r o s S o n i a B a r r o s S p e c i a l C o u n s e l