SEC Company Response from WNC HOUSING TAX CREDIT FUND VI LP SERIES 10 (CIK 0001156815) — Sep 16, 2005
WNC HOUSING TAX CREDIT FUND VI LP SERIES 10 (CIK 0001156815)
Date: Sept. 16, 2005 · CIK: 0001156815 · Accession: 0001084067-05-000144
AI Filing Summary & Sentiment
Referenced dates: April 19, 2005
Show Raw Text
<DOCUMENT>
<TYPE>CORRESP
<SEQUENCE>1
<FILENAME>filename1.txt
<TEXT>
September 16, 2005
Steven Jacobs, Branch Chief
Securities and Exchange Commission
Division of Corporation Finance
Mail Stop 04-09
100 F Street, NE
Washington, DC 20549
Re: WNC Housing Tax Credit Fund VI, L.P. Series 10
File No. 0-50837
Form 10-K for the year ended March 31, 2004
Forms 10-Q for the quarterly periods ended June 30, 2004,
September 30, 2004 and December 31, 2004
Dear Mr. Jacobs:
The registrant is in receipt of your letter dated April 19, 2005 respecting
the referenced matters. After further extensive review of the staff's concerns
included therein, including telephone conversations between the registrant's
professional advisers and the staff, the registrant has determined the Local
Limited Partnerships are VIEs under FASB Interpretation No. 46 - Revised,
Consolidation of Variable Interest Entities. In furtherance thereof, and for so
long as the current guidance is effective, in future filings the registrant
proposes to include the following in the footnotes to its financial statements:
As of March 31, 2004, the Partnership adopted FASB Interpretation No.
46 - Revised, Consolidation of Variable Interest Entities ("FIN46R").
FIN 46R provides guidance as to when a company should include the
assets, liabilities, and activities of a variable interest entity
("VIE") in its financial statements, and when a company should
disclose information about its relationship with a VIE. A VIE is a
legal structure used to conduct activities or hold assets, and a VIE
must be consolidated by a company if it is the primary beneficiary
because a primary beneficiary absorbs the majority of the entity's
expected losses, the majority of the expected residual returns, or
both.
Under FIN 46R, the Local Limited Partnerships in which the Partnership
invests are VIEs. However, management does not consolidate the
Partnership's interests in these VIE's under FIN46R, as the
Partnership is not considered the primary beneficiary. Rather, the
Partnership currently records the amount of the investment in the
Local Limited Partnerships as an asset in the balance sheet, and
recognizes its share of Local Limited Partnership income or loss in
the statement of operations.
<PAGE>
Steven Jacobs, Senior Staff Accountant
September 16, 2005
Page 2
The Partnership's balance in its investment in Local Limited
Partnerships, plus the risk of recapture of tax credits previously
recognized on these investments, represents its maximum exposure to
loss. The Partnership's exposure to loss is mitigated by the condition
and financial performance of the underlying properties, as well as the
strength of the Local General Partners and their guarantee against
credit recapture.
If the foregoing is not objected to by the staff, the registrant will file
its unfiled reports as soon as is practicable under the circumstances.
Please contact the undersigned if you have any further questions or
comments in these regards.
Very truly yours,
/s/ Thomas J. Riha,
-------------------
Senior Vice President - Chief Financial Officer,
WNC & Associates, Inc.
</TEXT>
</DOCUMENT>