SecProbe.io

April 5, 2013

Via E -mail
Ms. Farzana K. Mitchell
Executive V. P. – Chief Financial Officer  and Treasurer
CBL & Associates Properties, Inc.
2030 Hamilton Place Blvd., Suite 500
Chattanooga, TN 37421

Re: CBL & Associates Properties, Inc.
 Form 10-K for Fiscal Year Ended December 31, 2012
Filed March 1, 2013
File No. 1 -12494

Dear Ms. Mitchell :

We have reviewed your filing an d have the following comment .  In our comment , we
may ask you to provide us with information so we may better understand your disclosure.

Please respond to this letter within ten business days by providing the requested
information  or by advising us when you will provide the requested response.   If you do not
believe our comme nt applies  to your facts and circumstances , please tell us why in your
response.

After reviewing the information you provide in response to this comment , we may have
additional comments.

Note 14. Contingencies, page 115

1. In future Exchange Act reports, please revise to disclose the amount of reasonably
possible losses or range of losses in excess of amounts accrued for legal proceedings,
environmental re mediation obligations, and other contingencies or, where applicable, to
state that such an estimate of the possible loss or range of loss cannot be made.  Refer to
ASC 410 -30-50 and ASC 450 -20-50.

We urge all persons who are responsible for the accuracy a nd adequacy of the disclosure
in the filing to be certain that the filing includes the information the Securities Exchange Act of
1934 and all applicable Exchange Act rules require.   Since the company and its management are
in possession of all facts relat ing to a company’s disclosure, they are responsible for the accuracy
and adequacy of the disclosures they have made.

 In responding to our comment , please provide  a written statement from the company
acknowledging that:

Ms. Farzana K. Mitchell
CBL & Associates Properties, Inc.
April 5, 2013
Page 2

 the company is responsible for t he adequacy and accuracy of the disclosure in the filing;

 staff comments or changes to disclosure in response to staff comments 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.

You may contact Isaac Esquivel, Staff Accountant at (202) 551 -3395  or me at
(202) 551 -3694  if you have questions regarding comments on the financial statements and
related matters.

Sincerely,

 /s/ Jonathan Wiggins

Jonathan Wiggins
Staff Accountant