SEC Comment Letter for APARTMENT INVESTMENT & MANAGEMENT CO (AIV) (CIK 0000922864) (AIV) — May 30, 2012

APARTMENT INVESTMENT & MANAGEMENT CO (AIV) (CIK 0000922864)
Date: May 30, 2012 · CIK: 0000922864 · Accession: 0000000000-12-027988

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File numbers found in text: 001-13232

Date

May 30, 2012

Author

/s/ Daniel L. Gordon

Form

UPLOAD

Company

APARTMENT INVESTMENT & MANAGEMENT CO (AIV) (CIK 0000922864)

Letter

May 30 , 201 2 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 Ye ar Ended December 31, 20 11 Filed February 23 , 201 2 File No. 001-13232

Dear Mr. Freedman :

We have completed our review of your filings. We remind you that our comments or changes to disclosure in response to our comments do not foreclose the Commission from taking any action with respect to the company or the filing s 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. We urge all persons who are responsible for the accuracy and adequacy of the disclosure in the filings to be certain that the filing s include the information the Securities Exchange Act of 1934 and all applicable rules require.

Sincerely,
/s/ Daniel L. Gordon

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May 30 , 201 2

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 Ye ar Ended December  31, 20 11
Filed February 23 , 201 2
File No. 001-13232

Dear Mr.  Freedman :

We have completed our review of your filings.  We remind you that our
comments or changes to disclosure in response to our comments do not foreclose the
Commission from taking any action with respect to the company or the filing s 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.  We
urge all persons who are responsible for the accuracy and adequacy  of the disclosure in
the filings  to be certain that the filing s include the information the Securities Exchange
Act of 1934 and all applicable rules require.

                                                                                    Sincerely,

        /s/ Daniel L. Gordon

Daniel L. Gordon
                                                                                    Branch Chief

SecProbe.io