-----BEGIN PRIVACY-ENHANCED MESSAGE----- Proc-Type: 2001,MIC-CLEAR Originator-Name: webmaster@www.sec.gov Originator-Key-Asymmetric: MFgwCgYEVQgBAQICAf8DSgAwRwJAW2sNKK9AVtBzYZmr6aGjlWyK3XmZv3dTINen TWSM7vrzLADbmYQaionwg5sDW3P6oaM5D3tdezXMm7z1T+B+twIDAQAB MIC-Info: RSA-MD5,RSA, T0skPjlcsCW7ACkCRq915UKg6Zz0ukETh/p0WMoHdquSSnWdCedHuxDllrb0xgST JLiSL4XF66z6YWWOHFlO4Q== 0000000000-05-026051.txt : 20060823 0000000000-05-026051.hdr.sgml : 20060823 20050526100224 ACCESSION NUMBER: 0000000000-05-026051 CONFORMED SUBMISSION TYPE: UPLOAD PUBLIC DOCUMENT COUNT: 1 FILED AS OF DATE: 20050526 FILED FOR: COMPANY DATA: COMPANY CONFORMED NAME: NATIONAL HOUSING PARTNERSHIP REALTY FUND IV CENTRAL INDEX KEY: 0000780149 STANDARD INDUSTRIAL CLASSIFICATION: OPERATORS OF NONRESIDENTIAL BUILDINGS [6512] IRS NUMBER: 521473440 STATE OF INCORPORATION: MD FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: UPLOAD BUSINESS ADDRESS: STREET 1: 9200 KEYSTONE CROSSING STREET 2: SUITE 500 CITY: INDIANAPOLIS STATE: IN ZIP: 46240-7602 BUSINESS PHONE: 2023476247 MAIL ADDRESS: STREET 1: NHP INC STREET 2: 8065 LEESBURB PIKE CITY: VIENNA STATE: VA ZIP: 22182-2738 LETTER 1 filename1.txt Mail Stop 4561 May 25, 2005 VIA U.S. MAIL AND FAX (864) 239-5824 Mr. Stephen Waters Vice President National Corporation for Housing Partnerships 55 Beattie Place, PO Box 1089 Greenville, SC 29602 Re: National Housing Partnership Realty Fund IV Forms 10-KSB for the year ended December 31, 2004 File No. 0-15731 Dear Mr. Waters: We have reviewed your May 10, 2005 response letter and have the following additional comments. 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 comments or any other aspect of our review. Feel free to call us at the telephone numbers listed at the end of this letter. Form 10-KSB for the year ended December 31, 2004 Financial Statements and Notes Note 1 - Summary of Partnership Organization and Significant Accounting Policies Recent Accounting Pronouncements 1. We do not understand how the Partnership`s ability to remove the general partner has significant effect on the success of the entity in light of your response to comment 1 that the general partner has operating control and financial control through various rights and has "demonstrated exercise of that control ... over the twenty- year history of the local limited partnerships." Please clarify as these conclusions appear inconsistent. In addition, please tell us how various rights and obligations held by the general partner documented in your response to prior comment 1 impacted your analysis under paragraph 5(b). 2. It is unclear from your response how you reached your conclusions under paragraph 5(c). Please explain why you believe substantially all the activities of the local limited partnerships do not involve and are not conducted on behalf of you and NHP, collectively. In addition, please tell us what other parties are involved in the activities and for whose benefit they are conducted. You may contact Matthew Dowling, Staff Accountant, at (202) 551-3467 or me at (202) 551-3403 if you have questions. Please respond to the comments included in this letter within ten business days or tell us when you will provide us with a response. Please file your response on EDGAR. Sincerely, Steven Jacobs Accounting Branch Chief ?? ?? ?? ?? Mr. Stephen Waters National Housing Partnership Realty Fund IV May 25, 2005 Page 1 -----END PRIVACY-ENHANCED MESSAGE-----