June 23, 2025

Benjamin W. Jaenicke
Executive Vice President - Chief Financial Officer and Treasurer
CBL & Associates Properties, Inc.
2030 Hamilton Place Blvd., Suite 500
Chattanooga, TN 37421-6000

       Re: CBL & Associates Properties, Inc.
           Form 10-K for the year ended December 31, 2024
           Form 8-K Filed May 5, 2025
           File No. 001-12494
Dear Benjamin W. Jaenicke:

       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 8-K Filed May 5, 2025
Exhibit 99.1
Outlook and Guidance, page 4

1.     Reference is made to your presentation of Outlook and Guidance
information which
       includes 2025 Same-Center NOI. In future filings, please revise to
provide a
       reconciliation, to the extent available without unreasonable efforts, of
the differences
       between forward-looking Same-Center NOI and the most directly comparable
GAAP
       financial measure. Reference is made to Item 10(e)(1)(i)(B) of
Regulation S-K. To the
       extent you utilize the unreasonable efforts exception, please disclose
reliance upon the
       exception, identifying the information that is unavailable, and its
probable
       significance. Reference is made to Question 102.10(b) of the Compliance
and
       Disclosure Interpretations on Non-GAAP Financial Measures.
       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,
 June 23, 2025
Page 2

action or absence of action by the staff.

       Please contact Eric McPhee at 202-551-3693 or Wilson Lee at 202-551-3468
with any
questions.



                                                        Sincerely,

                                                        Division of Corporation
Finance
                                                        Office of Real Estate &
Construction