Securities Exchange Act of 1934
|Re:||KBS Legacy Partners Apartment REIT, Inc.|
Incoming letter dated July 16, 2018
Based on the facts presented, the Division will not object if KBS Legacy Partners Apartment REIT does not file future periodic reports under Section 13(a) or Section 15(d) of the Securities Exchange Act of 1934, beginning with its quarterly report on Form 10-Q for the period ended June 30, 2018. In reaching this position, we particularly note the following:
This position is based on the representations made to the Division in your letter. Any different facts or conditions might require the Division to reach a different conclusion. Further, this response expresses the Divisionís position on enforcement action only. It does not express any legal conclusion on the question presented. Having stated our views here and in several other letters regarding these modified reporting-related matters from REITs in liquidation, we do not intend to respond to letters relating to these or similar modified reporting-related matters from REITs in liquidation unless they present novel or unusual issues.
Courtney C. Haseley
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