SEC Comment Letter for APARTMENT INVESTMENT & MANAGEMENT CO (AIV) (CIK 0000922864) (AIV) — Jan 4, 2010
APARTMENT INVESTMENT & MANAGEMENT CO (AIV) (CIK 0000922864)
Date: Jan. 4, 2010 · CIK: 0000922864 · Accession: 0000000000-10-000163
AI Filing Summary & Sentiment
File numbers found in text: 000-24497, 001-13232
Referenced dates: November 17, 2009
Letter
Mail Stop 3010 January 4, 2010 VIA USMAIL and FAX (720) 493-6549 Mr. Paul Beldin Senior Vice President and Chief Accounting Officer Apartment Investment & Management Company AIMCO Properties, L.P. 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 AIMCO Properties, L.P. Form 10-K for the year ended 12/31/2008 Filed 2/27/2009 File Nos. 000-24497
Dear Mr. Paul Beldin: We have reviewed your response letters dated November 17, 2009 and have the following additional comment. If you disagree, we will consider your explanation as to why our comment is inapplicable. Provide to us the information requested if indicated and please be as detailed as necessary in your explanation.
FORM 10-K FOR THE YEAR ENDED DECEMBER 31, 2008
Financial Statements and Notes
Consolidated Statements of Income, page F-4
1. As it relates to your proposal to present the impairment losses within operating income in future filings, please supplementally confirm that in your 10-K for the fiscal year ended December 31, 2009, you will ensure all impacted financial statement columns are labeled as restated and you will provide all the required disclosures outlined in paragraph 250-10-50-7 of the FASB Accounting Standards Codification.
Paul Beldin Apartment Investment & Management Company AIMCO Properties, L.P. January 4, 2010 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 January 4, 2010 VIA USMAIL and FAX (720) 493-6549 Mr. Paul Beldin Senior Vice President and Chief Accounting Officer Apartment Investment & Management Company AIMCO Properties, L.P. 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 AIMCO Properties, L.P. Form 10-K for the year ended 12/31/2008 Filed 2/27/2009 File Nos. 000-24497 Dear Mr. Paul Beldin: We have reviewed your response letters dated November 17, 2009 and have the following additional comment. If you disagree, we will consider your explanation as to why our comment is inapplicable. Provide to us the information requested if indicated and please be as detailed as necessary in your explanation. FORM 10-K FOR THE YEAR ENDED DECEMBER 31, 2008 Financial Statements and Notes Consolidated Statements of Income, page F-4 1. As it relates to your proposal to present the impairment losses within operating income in future filings, please supplementally confirm that in your 10-K for the fiscal year ended December 31, 2009, you will ensure all impacted financial statement columns are labeled as restated and you will provide all the required disclosures outlined in paragraph 250-10-50-7 of the FASB Accounting Standards Codification. Paul Beldin Apartment Investment & Management Company AIMCO Properties, L.P. January 4, 2010 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