SEC Comment Letter for CNL RETIREMENT PROPERTIES INC (CIK 0001055264) — Dec 20, 2005
CNL RETIREMENT PROPERTIES INC (CIK 0001055264)
Date: Dec. 20, 2005 · CIK: 0001055264 · Accession: 0000000000-05-063131
AI Filing Summary & Sentiment
File numbers found in text: 000-32607
Referenced dates: October 6, 2005
Letter
December 20, 2005 VIA U.S. MAIL AND FAX (407)835-3232 Clark Hettinga Chief Financial Officer CNL Retirement Properties, Inc 450 South Orange Avenue Orlando, Florida 32801
Re: CNL Retirement Properties, Inc Form 10-K for Fiscal Year Ended December 31, 2004 Filed March 10, 2005 File No. 000-32607
Dear Mr. Hettinga:
We have reviewed your response letter dated October 6, 2005 and have the following additional comment. If you disagree with our comment, we will consider your explanation as to why our comment is not applicable. Please be as detailed as necessary in your explanation.
Please understand that the purpose of our review process is to assist you in your compliance with the applicable disclosure requirements and to enhance the overall disclosure in your filing. We look forward to working with you in these respects. We welcome any questions you may have about our comment or on any other aspect of our review. Feel free to call us at the telephone numbers listed at the end of this letter.
Form 10-K for the year ended December 31, 2004
1. We have considered your response to comment 1 and note that you track underlying operations of facilities on a property by property basis to evaluate performance and make decisions on the allocation of resources. Tell us your basis for aggregating the individual properties into a single segment under paragraph 17 of SFAS 131.
* * * *
Please respond to these comments within 10 business days or tell us when you will provide us with a response. Please understand that we may have additional comments after reviewing your responses to our comments.
You may contact Robert Telewicz, Staff Accountant, at (202) 551-3438 or the undersigned at (202) 551-3413 if you have questions.
Sincerely,
Cicely Luckey
Accounting Branch Chief
Show Raw Text
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<TYPE>LETTER
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<FILENAME>filename1.txt
<TEXT>
Mail Stop 4561
December 20, 2005
VIA U.S. MAIL AND FAX (407)835-3232
Clark Hettinga
Chief Financial Officer
CNL Retirement Properties, Inc
450 South Orange Avenue
Orlando, Florida 32801
Re: CNL Retirement Properties, Inc
Form 10-K for Fiscal Year Ended
December 31, 2004
Filed March 10, 2005
File No. 000-32607
Dear Mr. Hettinga:
We have reviewed your response letter dated October 6, 2005
and
have the following additional comment. If you disagree with our
comment, we will consider your explanation as to why our comment
is
not applicable. Please be as detailed as necessary in your
explanation.
Please understand that the purpose of our review process is
to
assist you in your compliance with the applicable disclosure
requirements and to enhance the overall disclosure in your filing.
We look forward to working with you in these respects. We welcome
any questions you may have about our comment or on any other
aspect
of our review. Feel free to call us at the telephone numbers
listed
at the end of this letter.
Form 10-K for the year ended December 31, 2004
1. We have considered your response to comment 1 and note that you
track underlying operations of facilities on a property by
property
basis to evaluate performance and make decisions on the allocation
of
resources. Tell us your basis for aggregating the individual
properties into a single segment under paragraph 17 of SFAS 131.
* * * *
Please respond to these comments within 10 business days or
tell us when you will provide us with a response. Please
understand
that we may have additional comments after reviewing your
responses
to our comments.
You may contact Robert Telewicz, Staff Accountant, at (202)
551-3438 or the undersigned at (202) 551-3413 if you have
questions.
Sincerely,
Cicely Luckey
Accounting Branch Chief
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Clark Hettinga
CNL Retirement Properties Inc.
December 20, 2005
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