SEC Comment Letter for APARTMENT INVESTMENT & MANAGEMENT CO (AIV) (CIK 0000922864) (AIV) — Jun 13, 2017
APARTMENT INVESTMENT & MANAGEMENT CO (AIV) (CIK 0000922864)
Date: June 13, 2017 · CIK: 0000922864 · Accession: 0000000000-17-020637
AI Filing Summary & Sentiment
Letter
Mail Stop 3233 June 13 , 2017 Via E -mail Paul Beldin Executive Vice President and Chief Financial Officer Apartment Investment and Management Company and AIMCO Properties, L.P. 4582 South Ulster Street, Suite 1100 Denver, CO 80237
Re: Apartment I nvestment and Management Company Form 10-K for the Year Ended December 31, 2016 Filed February 24, 2017 Form 8 -K Filed February 2, 2017 File No. 1-13232
Dear Mr. Beldin :
We have limited our review of your filing to the financial statements and related disclosures and have the following comments. In some of our comments, we may ask you to provide us with information so we may better understand your disclosure.
Please respond to these com ments within ten busine ss days by providing the requested information or advis e us as soon as possible when you will respond. If you do not believe our comments apply to your facts and circumstances, please tell us why in your response.
After reviewing your response to these comments, we may have additional comments.
Non-GAAP Measures, page 30
Economic Income, page 32
1. We note your disclosure in footnote 1 and that you value your communities using a variety of methods including applying m arket -based capitalization rates to annualized community NOI, discounted future cash flows and contract price. Please disclose the key assumptions, inputs and the weighting of each method used compared to the total fair value presented. Also, disclose the number of properties valued under each methodology and the percentage of fair value that is calculated using such methodology. Finally, include within your revised disclosure the characteristics of the communities that would cause the company to choose on e valuation method over another.
Paul Beldin Apartment Investment and Management Company and AIMCO Properties, L.P. June 13 , 2017 Page 2
2. We note your disclosure in footnote 2. Please disclose the interest and markets rates used to value your debt as well as any additional key assumptions and inputs. Also, please clarify why the fair value of debt is not the same as the fair value disclosed in your quarterly report for the period ended September 30, 2016.
Form 8 -K filed February 2, 2017
Exhibit 99.1
Leverage Ratio Definitions, page 37
3. We note your description of EBITDA and the related reconciliation on page 39. In future earnings releases, please revise your disclosure to identify this measure as Adjusted EBITDA.
We remind you that the company and its management are responsible for t he accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the staff.
You may contact William Demarest, Staff Accountant at 202 -551-3432 or me at 202- 551-3856 with any questions.
Sincerely,
/s/ Shannon Sobotka
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Mail Stop 3233
June 13 , 2017
Via E -mail
Paul Beldin
Executive Vice President and Chief Financial Officer
Apartment Investment and Management Company and AIMCO Properties, L.P.
4582 South Ulster Street, Suite 1100
Denver, CO 80237
Re: Apartment I nvestment and Management Company
Form 10-K for the Year Ended December 31, 2016
Filed February 24, 2017
Form 8 -K
Filed February 2, 2017
File No. 1-13232
Dear Mr. Beldin :
We have limited our review of your filing to the financial statements and related
disclosures and have the following comments. In some of our comments, we may ask you to
provide us with information so we may better understand your disclosure.
Please respond to these com ments within ten busine ss days by providing the requested
information or advis e us as soon as possible when you will respond. If you do not believe our
comments apply to your facts and circumstances, please tell us why in your response.
After reviewing your response to these comments, we may have additional comments.
Non-GAAP Measures, page 30
Economic Income, page 32
1. We note your disclosure in footnote 1 and that you value your communities using a
variety of methods including applying m arket -based capitalization rates to annualized
community NOI, discounted future cash flows and contract price. Please disclose the key
assumptions, inputs and the weighting of each method used compared to the total fair
value presented. Also, disclose the number of properties valued under each methodology
and the percentage of fair value that is calculated using such methodology. Finally,
include within your revised disclosure the characteristics of the communities that would
cause the company to choose on e valuation method over another.
Paul Beldin
Apartment Investment and Management Company and AIMCO Properties, L.P.
June 13 , 2017
Page 2
2. We note your disclosure in footnote 2. Please disclose the interest and markets rates used
to value your debt as well as any additional key assumptions and inputs. Also, please
clarify why the fair value of debt is not the same as the fair value disclosed in your
quarterly report for the period ended September 30, 2016.
Form 8 -K filed February 2, 2017
Exhibit 99.1
Leverage Ratio Definitions, page 37
3. We note your description of EBITDA and the related reconciliation on page 39. In future
earnings releases, please revise your disclosure to identify this measure as Adjusted
EBITDA.
We remind you that the company and its management are responsible for t he accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action or absence of
action by the staff.
You may contact William Demarest, Staff Accountant at 202 -551-3432 or me at 202-
551-3856 with any questions.
Sincerely,
/s/ Shannon Sobotka
Shannon Sobotka
Staff Accountant
Office of Real Estate
& Commodities