SEC Comment Letter for APARTMENT INVESTMENT & MANAGEMENT CO (AIV) (CIK 0000922864) (AIV) — Jul 6, 2009
APARTMENT INVESTMENT & MANAGEMENT CO (AIV) (CIK 0000922864)
Date: July 6, 2009 · CIK: 0000922864 · Accession: 0000000000-09-035433
AI Filing Summary & Sentiment
File numbers found in text: 001-13232
Referenced dates: June 2, 2009
Letter
Mail Stop 3010 July 1, 2009 VIA USMAIL and FAX (720) 493-6549 Mr. Paul Beldin Senior Vice President and Chief Accounting Officer Apartment Investment & Management Company 4582 South Ulster Street Parkway, Suite 1100 Denver, Colorado 80237 Re: Apartment Investment & Management Company Form 10-K for the year ended 12/31/2008 Filed 2/27/2009 File Nos. 001-13232
Dear Mr. Paul Beldin: We have reviewed your response letter dated June 2, 2009 and have the following additional comment. Where indicated, we think you should revise your documents in response to this comment. If you disagree, we will consider your explanation as to why our comment is inapplicable or a revision is unnecessary. Provide to us the information requested if indicated and please be as detailed as necessary in your explanation. Financial Statements and Notes
Consolidated Statements of Income, page F-4 1. We have considered your response to comment one. We continue to believe the presentation of the impairment losses as a part of operating income is appropriate. Given the large amounts of your impairment losses, we are unable to agree with your materiality analysis. Please revise your filing accordingly to reclass the provision for impairment losses for operating real estate and real estate development assets within operating income and tell us your consideration regarding any requirements to file an Item 4.02 8-K.
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Paul Beldin Apartment Investment & Management Company July 1, 2009 Page
As appropriate, please respond to this comment within 10 business days or tell us when you will provide us with a response. Please file a letter that keys your responses to our comment and provides any requested information. Detailed cover letters greatly facilitate our review. Please file your letter on EDGAR. Please understand that we may have additional comments after reviewing your responses to our comment. You may contact Wilson K. Lee at (202) 551-3468 or me at (202) 551-3413 if you have any questions. Sincerely,
Cicely LaMothe Branch Chief
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Mail Stop 3010 July 1, 2009 VIA USMAIL and FAX (720) 493-6549 Mr. Paul Beldin Senior Vice President and Chief Accounting Officer Apartment Investment & Management Company 4582 South Ulster Street Parkway, Suite 1100 Denver, Colorado 80237 Re: Apartment Investment & Management Company Form 10-K for the year ended 12/31/2008 Filed 2/27/2009 File Nos. 001-13232 Dear Mr. Paul Beldin: We have reviewed your response letter dated June 2, 2009 and have the following additional comment. Where indicated, we think you should revise your documents in response to this comment. If you disagree, we will consider your explanation as to why our comment is inapplicable or a revision is unnecessary. Provide to us the information requested if indicated and please be as detailed as necessary in your explanation. Financial Statements and Notes Consolidated Statements of Income, page F-4 1. We have considered your response to comment one. We continue to believe the presentation of the impairment losses as a part of operating income is appropriate. Given the large amounts of your impairment losses, we are unable to agree with your materiality analysis. Please revise your filing accordingly to reclass the provision for impairment losses for operating real estate and real estate development assets within operating income and tell us your consideration regarding any requirements to file an Item 4.02 8-K. * * * * Paul Beldin Apartment Investment & Management Company July 1, 2009 Page 2 As appropriate, please respond to this comment within 10 business days or tell us when you will provide us with a response. Please file a letter that keys your responses to our comment and provides any requested information. Detailed cover letters greatly facilitate our review. Please file your letter on EDGAR. Please understand that we may have additional comments after reviewing your responses to our comment. You may contact Wilson K. Lee at (202) 551-3468 or me at (202) 551-3413 if you have any questions. Sincerely, Cicely LaMothe Branch Chief