SEC Company Response from APARTMENT INVESTMENT & MANAGEMENT CO (AIV) (CIK 0000922864) (AIV) — Dec 19, 2011
APARTMENT INVESTMENT & MANAGEMENT CO (AIV) (CIK 0000922864)
Date: Dec. 19, 2011 · CIK: 0000922864 · Accession: 0000950123-11-103469
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 333-175843, 333-175847, 333-175848, 333-175853
Letter
VIA EDGAR Division of Corporation Finance Securities and Exchange Commission AIMCO Properties, L.P. Registration Statement on Form S-4 Filed July 28, 2011 File No.: 333-175847
Dear Mr. Turk:
Apartment Investment and Management Company (“Aimco”) and AIMCO Properties, L.P. (“Aimco OP”) are today filing an amendment to the Registration Statement (File No. 333-175847) on Form S-4 (the “NPI 4 Form S-4”) referenced above. The NPI 4 Form S-4 relates to the merger of National Property Investors 4.
We hereby confirm, on behalf of Aimco and Aimco OP, that the changes made to the NPI 4 Form S-4 are similar in nature to those that were previously made by Aimco and Aimco OP in the amendments to three Registration Statements on Form S-4 (File Nos. 333-175843, 333-175848 and 333-175853), filed with the Securities and Exchange Commission on November 15, 2011 (the “Prior Filings”). The changes made to the NPI 4 Form S-4 (including opinions filed as exhibits) respond to the Staff’s comments in the same manner as the Prior Filings.
* * * *
If you have any questions regarding the foregoing, please contact Robert Mintz at (303) 899-7399.
Mr. Adem F. Trunk
Securities and Exchange Commission
December 19,2011
Page 2
Respectfully yours,
/s/ Robert Mintz
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Hogan Lovells US LLP
One Tabor Center, Suite 1500
1200 Seventeenth Street
Denver, CO 80202
T +1 303 899 7300
F +1 303 899 7333
www.hoganlovells.com
December 19, 2011
VIA EDGAR
Adam F. Turk, Attorney-Advisor
Division of Corporation Finance
Securities and Exchange Commission
100 F. Street, N.E.
Washington, D.C. 20549
Re:
Apartment Investment and Management Company
AIMCO Properties, L.P.
Registration Statement on Form S-4
Filed July 28, 2011
File No.: 333-175847
Dear Mr. Turk:
Apartment Investment and Management Company (“Aimco”) and AIMCO Properties, L.P.
(“Aimco OP”) are today filing an amendment to the Registration Statement (File No.
333-175847) on Form S-4 (the “NPI 4 Form S-4”) referenced above. The NPI 4 Form S-4
relates to the merger of National Property Investors 4.
We hereby confirm, on behalf of Aimco and Aimco OP, that the changes made to the NPI 4 Form
S-4 are similar in nature to those that were previously made by Aimco and Aimco OP in the
amendments to three Registration Statements on Form S-4 (File Nos. 333-175843, 333-175848 and
333-175853), filed with the Securities and Exchange Commission on November 15, 2011 (the “Prior
Filings”). The changes made to the NPI 4 Form S-4 (including opinions filed as exhibits)
respond to the Staff’s comments in the same manner as the Prior Filings.
* * * *
If you have any questions regarding the foregoing, please contact Robert Mintz at (303)
899-7399.
Mr. Adem F. Trunk
Securities and Exchange Commission
December 19,2011
Page 2
Respectfully yours,
/s/ Robert Mintz
Robert Mintz
cc:
John Bezzant, Executive Vice President
Apartment Investment and Management Company
Trent Johnson, Vice President and Assistant General Counsel
Apartment Investment and Management Company