SecProbe.io

March 16, 2012
                                                                                                  Via E-Mail

Ernest M. Freedman Chief Financial Officer Apartment Investment and Management Company  4582 South Ulster Street Parkway, Suite 1100 Denver, CO  80237
                 Re: Apartment Investment and Management Company
Form 10-K for the Fiscal Year Ended December 31, 2011 Filed February 23, 2012 File No. 001-13232

Dear Mr. Freedman:

We have reviewed your filing and have the following comments.  In some of our
comments, we may ask you to provide us w ith information so we may better understand
your disclosure.
 Please respond to this letter within ten business days by amending your filing, by
providing the requested information, or by advising us when you will provide the requested response.  If you do not believe  our comments apply to your facts and
circumstances or do not believe an amendment is appropriate, please tell us why in your
response.
 After reviewing any amendment to your filing and the information you provide in
response to these comments, we ma y have additional comments.

Form 10-K for the Fiscal Year Ended December 31, 2011 filed February 23, 2012

 Capitalized Costs, page 32

 1. Please tell us, and disclose as part of your critical accounting policies and
significant accounting policies in future filings, the capitalization period including when the capitalization period begins and ends and how that is determined.
 Funds From Operations, Pro forma Funds Fr om Operations and Adjusted Funds From
Operations, page 32
 2. We note your disclosure that computation of AFFO is subject to definitions of
capital spending, which are subjective. Please tell us, and disclose in future

Ernest M. Freedman
Apartment Investment and Management Company
March 16, 2012 Page 2

 filings, how you define capital replacem ents and how you determine the amount
included in the computation of AFFO.
 Investing Activities, page 35

 3. In future filings please expand your disclo sure to include additional analysis of
your capital expenditures breaking them  down between new development,
redevelopment/renovations, and other cap ital expenditures (i .e. capitalized
interest, capitalized payroll, etc.) by year .  In addition please provide a narrative
discussion for fluctuations from year to y ear and expectations for the future.  The
total of these capitalized  expenditures should reconcile to the capitalized
expenditures included in cash flow fr om investing activities within the
consolidated statement of cash flows.

We urge all persons who are responsible for the accuracy and 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 Exch ange Act rules require.  Since the company
and its management are in possession of all f acts relating to a company’s disclosure, they
are responsible for the accuracy and adequacy  of the disclosures they have made.

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

 the company is responsible for the 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 comme nts as a defense in any proceeding
initiated by the Commission or any person under the federal secu rities laws of the
United States.

 If you have any questions, you may contact  Jorge L. Bonilla at (202) 551-3414 or
me at (202) 551-3486.

                                                                                     Sincerely,                                                                                                       /s/ Daniel L. Gordon
Daniel L. Gordon
                                                                                    Branch Chief