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: 0001193125-11-345207
AI Filing Summary & Sentiment
File numbers found in text: 333-175843, 333-175846, 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.: 333-175846
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. 333-175846) on Form S-4 (the “CPF XVII Form S-4”) referenced above. The CPF XVII Form S-4 relates to the merger of Century Properties Fund XVII, LP.
We hereby confirm, on behalf of Aimco and Aimco OP, that the changes made to the CPF XVII 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 XVII Form S-4 (including opinions filed as exhibits) respond to the Staff’s comments in the same manner as the Prior Filings.
* * * *
Mr. Adam F. Turk
Securities and Exchange Commission
December 19, 2011
Page 2
If you have any questions regarding the foregoing, please contact Jonathan Friedman at (213) 687-5396 or the undersigned at (213) 687-5567.
Respectfully yours,
/s/ Nicolai Schwarz-Gondek
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CORRESP
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CORRESPONDENCE
SKADDEN, ARPS, SLATE, MEAGHER &
FLOM LLP
300 SOUTH GRAND AVENUE
LOS ANGELES, CALIFORNIA 90071-3144
________
FIRM/AFFILIATE
OFFICES
________
TEL: (213) 687-5000
FAX: (213) 687-5600
www.skadden.com
December 19,
2011
BOSTON
CHICAGO
HOUSTON
NEW
YORK
PALO ALTO
WASHINGTON, D.C.
WILMINGTON
________
BEIJING
BRUSSELS
FRANKFURT
HONG
KONG
LONDON
MOSCOW
MUNICH
PARIS
SÃO
PAULO
SHANGHAI
SINGAPORE
SYDNEY
TOKYO
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.:
333-175846
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. 333-175846) on Form S-4 (the “CPF XVII Form S-4”) referenced above. The CPF XVII Form S-4 relates to the merger of Century Properties Fund XVII, LP.
We hereby confirm, on behalf of Aimco and Aimco OP, that the changes made to the CPF XVII 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 XVII Form S-4 (including opinions filed as exhibits) respond to the Staff’s comments in the same manner as the Prior Filings.
* * *
*
Mr. Adam F. Turk
Securities and Exchange Commission
December 19, 2011
Page 2
If you have any
questions regarding the foregoing, please contact Jonathan Friedman at (213) 687-5396 or the undersigned at (213) 687-5567.
Respectfully yours,
/s/ Nicolai Schwarz-Gondek
Nicolai Schwarz-Gondek
cc:
John Bezzant, Executive Vice President
Apartment Investment and Management Company
Trent Johnson, Vice President and Assistant General Counsel
Apartment Investment and Management Company