SEC Comment Letter for APARTMENT INVESTMENT & MANAGEMENT CO (AIV) (CIK 0000922864) (AIV) — Jun 30, 2017
APARTMENT INVESTMENT & MANAGEMENT CO (AIV) (CIK 0000922864)
Date: June 30, 2017 · CIK: 0000922864 · Accession: 0000000000-17-023018
AI Filing Summary & Sentiment
Letter
Mail Stop 3233 June 30, 2017 Via E -mail Paul L. 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 Form 8 -K filed February 2, 2017 Response Dated June 26, 2017 File No. 1-13232
Dear Mr. Beldin :
We have reviewed your June 26, 2017 response to our comment letter and have the following comment s. 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 comments 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. Unless we note otherwise, our references to prior comments are to c omments in our June 13, 2017 letter .
Item 7. Management’s Discussion and Analysis of Financial Condition and Results of Operations
Non-GAAP Measures, page 30
Economic Income, page 32
1. We note your response to our prior comment 1. Please provide to us and include within future filings the following:
a reconciliation from consolidated apartment communities to the number included in your NAV calculation
Paul L. Beldin Apartment Investment and Management Company and AIMCO Properties, L.P. June 30, 2017 Page 2
an explanation of why certain consolidated apartment communities are excluded from your NAV calculation clarification, if true, that the fair value of your real estate, like your debt, is presented on a proportional basis the fair value of your asset management business
2. We note your response to our prior comment 2. We remain unclear from footnote 5 how the non -recourse debt of consolidated partnerships for whom the Company provides asset management and other services is factored into the value of the asset management business. Please clarify and revise your disclosure in future filings.
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 30, 2017
Via E -mail
Paul L. 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
Form 8 -K filed February 2, 2017
Response Dated June 26, 2017
File No. 1-13232
Dear Mr. Beldin :
We have reviewed your June 26, 2017 response to our comment letter and have the
following comment s. 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 comments 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.
Unless we note otherwise, our references to prior comments are to c omments in our June 13,
2017 letter .
Item 7. Management’s Discussion and Analysis of Financial Condition and Results of
Operations
Non-GAAP Measures, page 30
Economic Income, page 32
1. We note your response to our prior comment 1. Please provide to us and include within
future filings the following:
a reconciliation from consolidated apartment communities to the number included in
your NAV calculation
Paul L. Beldin
Apartment Investment and Management Company and AIMCO Properties, L.P.
June 30, 2017
Page 2
an explanation of why certain consolidated apartment communities are excluded from
your NAV calculation
clarification, if true, that the fair value of your real estate, like your debt, is presented
on a proportional basis
the fair value of your asset management business
2. We note your response to our prior comment 2. We remain unclear from footnote 5 how
the non -recourse debt of consolidated partnerships for whom the Company provides asset
management and other services is factored into the value of the asset management
business. Please clarify and revise your disclosure in future filings.
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