SEC Comment Letter 0000000000-24-006180 to ERP OPERATING LTD PARTNERSHIP (CIK 0000931182)
ERP OPERATING LTD PARTNERSHIP (CIK 0000931182)
Date: May 29, 2024 · CIK: 0000931182 · Accession: 0000000000-24-006180
AI Filing Summary & Sentiment
File numbers found in text: 000-24920, 001-12252
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United States securities and exchange commission logo
May 29, 2024
Robert A. Garechana
Executive Vice President and Chief Financial Officer
Equity Residential
Two North Riverside Plaza
Chicago, Illinois 60606
Re:Equity Residential
ERP Operating Limited Partnership
Form 10-K for the fiscal year ended December 31, 2023
Filed February 15, 2024
File No. 001-12252
File No. 000-24920
Dear Robert A. Garechana:
We have limited our review of your filing to the financial statements and related
disclosures and have the following comment.
Please respond to this letter within ten business days by providing the requested
information or advise us as soon as possible when you will respond. If you do not believe a
comment applies to your facts and circumstances, please tell us why in your response.
After reviewing your response to this letter, we may have additional comments.
Form 10-K for fiscal year ended December 31, 2023
Item 8. Financial Statements and Supplementary Data
Consolidated Financial Statements
Notes to Consolidated Financial Statements
17. Reportable Segments, page F-56
1.We note you do not appear to provide a reconciliation for your segment measure of profit
or loss of Net operating income. In future periodic filings, including your subsequent
interim Form 10-Q filings, please provide a reconciliation to reconcile your segment
measure to Net (loss) income before income tax. Refer to ASC 280-10-50-30b.
In closing, we remind you that the company and its management are responsible for the
accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or
absence of action by the staff.
FirstName LastNameRobert A. Garechana
Comapany NameEquity Residential
May 29, 2024 Page 2
FirstName LastName
Robert A. Garechana
Equity Residential
May 29, 2024
Page 2
Please contact Peter McPhun at 202-551-3581 or Mark Rakip at 202-551-3573 with any
questions.
Sincerely,
Division of Corporation Finance
Office of Real Estate & Construction