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: 0000950123-11-103472
AI Filing Summary & Sentiment
File numbers found in text: 333-175843, 333-175848, 333-175850, 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.: 333-175850
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. 333-175850) on Form S-4 (the “CPF XV Form S-4”) referenced above. The CPF XV Form S-4 relates to the merger of Century Properties Fund XV, LP.
We hereby confirm, on behalf of Aimco and Aimco OP, that the changes made to the CPF XV 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 CPF XV 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 the undersigned at (404) 881-7451.
Atlanta • Brussels • Charlotte • Dallas • Los Angeles • New York • Research Triangle • Silicon Valley • Ventura County • Washington, D.C.
December 19, 2011
Page 2
Respectfully yours,
/s/ Paul J. Nozick
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One Atlantic Center
1201 West Peachtree Street
Atlanta, GA 30309-3424
404-881-7000
Fax: 404-881-7777
www.alston.com
Paul J. Nozick
Direct Dial: 404-881-7451
Email: paul.nozick@alston.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.: 333-175850
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. 333-175850) on Form S-4 (the “CPF XV Form S-4”) referenced above. The CPF XV Form S-4
relates to the merger of Century Properties Fund XV, LP.
We hereby confirm, on behalf of Aimco and Aimco OP, that the changes made to the CPF XV 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 CPF XV 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 the undersigned at (404)
881-7451.
Atlanta • Brussels • Charlotte • Dallas • Los Angeles • New York • Research Triangle • Silicon Valley • Ventura County • Washington, D.C.
December 19, 2011
Page 2
Respectfully yours,
/s/ Paul J. Nozick
Paul J. Nozick
cc:
John Bezzant, Executive Vice President
Apartment Investment and Management Company
Trent Johnson, Vice President and Assistant General Counsel
Apartment Investment and Management Company