SEC Company Response from APARTMENT INVESTMENT & MANAGEMENT CO (AIV) (CIK 0000922864) (AIV) — Jan 15, 2010
APARTMENT INVESTMENT & MANAGEMENT CO (AIV) (CIK 0000922864)
Date: Jan. 15, 2010 · CIK: 0000922864 · Accession: 0000950123-10-002913
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 000-24497, 001-13232
Referenced dates: January 4, 2010
Letter
Correspondence
APARTMENT INVESTMENT AND MANAGEMENT COMPANY
AIMCO PROPERTIES, L.P.
4582 South Ulster Street Parkway, Suite 1100
Denver, Colorado 80237
January 15, 2010
Correspondence Filing Via Edgar
United States Securities and Exchange Commission
Division of Corporation Finance
Mail Stop 4561
450 Fifth Street, NW
Washington, D.C. 20549
Attn: Cicely LaMothe
Wilson K. Lee
Re:
Apartment Investment and Management Company
File No. 001-13232
Form 10-K for the year ended December 31, 2008
AIMCO Properties, L.P.
File No. 000-24497
Form 10-K for the year ended December 31, 2008
Ladies & Gentlemen:
This letter responds to the comment of the staff of the Securities and Exchange Commission (the “Staff”) addressed to Paul Beldin on behalf of Apartment Investment and Management Company (“Aimco”) and AIMCO Properties, L.P., a Delaware limited partnership (collectively, the “Companies”), in a letter dated January 4, 2010. The Companies’ response to the Staff’s comment is set forth below.
* * * * *
United States Securities and Exchange Commission
January 15, 2010
Page 2 of 2
Form 10-K for the year ended December 31, 2008
Financial Statements and Notes
Consolidated Statements of Income, page F-4
1.
Comment: As it relates to your proposal to present the impairment losses within operating income in future filings, please supplementally confirm that in your 10-K for the fiscal year ended December 31, 2009, you will ensure all impacted financial statement columns are labeled as restated and you will provide all the required disclosures outlined in paragraph 250-10-50-7 of the FASB Accounting Standards Codification.
Response: In response to the Staff’s comment, the Companies confirm that in their Forms 10-K for the year ended December 31, 2009, they will ensure all affected financial statement columns are labeled as restated and they will provide the required disclosures outlined in paragraph 250-10-50-7 of the FASB Accounting Standards Codification.
If you have further questions regarding the information provided, please contact Ernie Freedman, Executive Vice President and Chief Financial Officer, at (303) 691-4316 (phone) or (720) 493-6545 (facsimile) or me at (303) 691-4554 (phone) or (720) 493-6549 (facsimile).
Sincerely,
/s/ Paul Beldin
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Correspondence
APARTMENT INVESTMENT AND MANAGEMENT COMPANY
AIMCO PROPERTIES, L.P.
4582 South Ulster Street Parkway, Suite 1100
Denver, Colorado 80237
January 15, 2010
Correspondence Filing Via Edgar
United States Securities and Exchange Commission
Division of Corporation Finance
Mail Stop 4561
450 Fifth Street, NW
Washington, D.C. 20549
Attn: Cicely LaMothe
Wilson K. Lee
Re:
Apartment Investment and Management Company
File No. 001-13232
Form 10-K for the year ended December 31, 2008
AIMCO Properties, L.P.
File No. 000-24497
Form 10-K for the year ended December 31, 2008
Ladies & Gentlemen:
This letter responds to the comment of the staff of the Securities and Exchange Commission (the “Staff”) addressed
to Paul Beldin on behalf of Apartment Investment and Management Company (“Aimco”) and AIMCO Properties, L.P., a
Delaware limited partnership (collectively, the “Companies”), in a letter dated January 4, 2010. The Companies’
response to the Staff’s comment is set forth below.
* * * * *
1
United States Securities and Exchange Commission
January 15, 2010
Page 2 of 2
Form 10-K for the year ended December 31, 2008
Financial Statements and Notes
Consolidated Statements of Income, page F-4
1.
Comment: As it relates to your proposal to present the impairment losses within operating income in future
filings, please supplementally confirm that in your 10-K for the fiscal year ended December 31, 2009, you will
ensure all impacted financial statement columns are labeled as restated and you will provide all the required
disclosures outlined in paragraph 250-10-50-7 of the FASB Accounting Standards Codification.
Response: In response to the Staff’s comment, the Companies confirm that in their Forms 10-K for the year ended
December 31, 2009, they will ensure all affected financial statement columns are labeled as restated and they will
provide the required disclosures outlined in paragraph 250-10-50-7 of the FASB Accounting Standards Codification.
If you have further questions regarding the information provided, please contact Ernie Freedman, Executive Vice
President and Chief Financial Officer, at (303) 691-4316 (phone) or (720) 493-6545 (facsimile) or me at (303) 691-4554
(phone) or (720) 493-6549 (facsimile).
Sincerely,
/s/ Paul Beldin
Paul Beldin
Chief Accounting Officer of Aimco and AIMCO-GP, Inc.,
the general partner of AIMCO Properties, L.P.
Cc:
Amy B. Freed, Hogan & Hartson LLP
Lisa R. Cohn, Aimco
Ernie Freedman, Aimco
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