SEC Company Response from HOME PROPERTIES INC (CIK 0000923118) — Sep 16, 2005
HOME PROPERTIES INC (CIK 0000923118)
Date: Sept. 16, 2005 · CIK: 0000923118 · Accession: 0000923118-05-000167
AI Filing Summary & Sentiment
File numbers found in text: 333-127648
Referenced dates: August 29, 2005
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CORRESP
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September 16, 2005
United States Securities and Exchange Commission
Division of Corporation Finance
Washington, DC 20549
Mail Stop 4561
Attn: David H. Roberts
Re: Home Properties, Inc.
Registration Statement on Form S-3 (Registration No. 333-127648
Filed on August 18, 2005, Amendment filed September 8, 2005
Ladies and Gentlemen:
In accordance with Rule 461 of Regulation C promulgated under the Securities Act
of 1933, as amended, Home Properties, Inc. hereby requests acceleration of the
effectiveness of the above-captioned Registration Statement to become effective
on Wednesday, September 21, 2005 at 9:00 a.m., or as soon as practicable
thereafter.
In connection with this request for acceleration and as requested in the comment
letter from the staff, dated August 29, 2005, the Company acknowledges that:
- if the Securities and Exchange Commission or its staff, acting
pursuant to delegated authority, declares the filing of the
Registration Statement on Form S-3 (No. 333-127648) effective, such
action does not preclude the Commission from taking any action with
respect to the filing;
- the action by the Commission or its staff, acting pursuant to
delegated authority, in declaring the filing effective, does not
relieve the Company from its full responsibility for the adequacy and
accuracy of the disclosure in the filing; and
- the Company may not assert staff comments and the declaration of
effectiveness as a defense in any proceeding initiated by the
Commission or any person under the federal securities laws of the
United States.
Please call me or our counsel, Deborah McLean Quinn at Nixon Peabody LLP,
585-263-1307 with any questions or comments.
Very truly yours,
HOME PROPERTIES, INC.
/s/ Ann M. McCormick
Ann M. McCormick
Executive Vice President, Secretary and General Counsel