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SEC Comment Letter for APARTMENT INVESTMENT & MANAGEMENT CO (AIV) (CIK 0000922864) (AIV) — May 23, 2013

APARTMENT INVESTMENT & MANAGEMENT CO (AIV) (CIK 0000922864)
Date: May 23, 2013 · CIK: 0000922864 · Accession: 0000000000-13-028533

AI Filing Summary & Sentiment

Sentiment
Urgency
Document Type
Confidence
SEC Posture
Company Posture

Summary

Reasoning

Date
May 23, 2013
Author
/s/ Daniel L. Gordon
Form
UPLOAD
Company
APARTMENT INVESTMENT & MANAGEMENT CO (AIV) (CIK 0000922864)

Letter

May 23, 2013 Via Email Mr. Paul Beldin Chief Accounting Officer Apartment Investment and Management Company 4582 South Ulster Street Suite 1100 Denver, CO 80237

Re: Apartment Investment and Management Company Form 10-K Filed February 25, 2013 File No. 001 -13232

Dear Mr. Beldin :

We have completed our review of your filing . 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 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 filing to be certain that the filing includes the information the Securities Exchange Act of 1934 and all applicable rules require.

Sincerely,
/s/ Daniel L. Gordon

Show Raw Text
May 23, 2013

Via Email
Mr. Paul Beldin
Chief Accounting Officer
Apartment Investment and Management Company
4582 South Ulster Street
Suite 1100
Denver, CO  80237

Re: Apartment Investment and Management Company
 Form 10-K
Filed February 25, 2013
File No. 001 -13232

Dear Mr. Beldin :

We have completed our review of your filing .  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 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 filing to be certain that the filing includes the
information the Securities Exchange Act of 1934 and all applicable rules require.

Sincerely,

 /s/ Daniel L. Gordon

Daniel L. Gord on
Branch Chief