December 17, 2018

John A. Isakson
Chief Financial Officer
Preferred Apartment Communities, Inc.
3284 Northside Parkway NW
Suite 150
Atlanta, GA 30327

       Re: Preferred Apartment Communities, Inc.
           Form 10-K for the Fiscal Year Ended December 31, 2017
           Filed March 1, 2018
           File No. 1-34995

Dear Mr. Isakson:

       We have limited our review of your filing to the financial statements
and related
disclosures and have the following comment. In some of our comments, we may ask
you to
provide us with information so we may better understand your disclosure.

       Please respond to this comment 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 our
comment applies to your facts and circumstances, please tell us why in your
response.

       After reviewing your response to these comments, we may have additional
comments.

Form 10-K for the Fiscal Year Ended December 31, 2017

Item 7. Management's Discussion and Analysis of Financial Condition and Results
of
Operations
Reconciliation of FFO, Core FFO and AFFO to Net Income (Loss) Attributable to
Common
Stockholders, page 67

1.    We note that you reconcile funds from operations (FFO) from net income
(loss)
      attributable to common stockholders and it appears FFO represents FFO
attributable to
      common stockholders and unitholders. In future filings please revise the
label of this non-
      GAAP measure in your reconciliation to indicate that it is FFO
attributable to common
      shareholders and unitholders. This comment is also applicable to the
extent this measure is
      presented in your earnings release filed on Form 8-K.
 John A. Isakson
Preferred Apartment Communities, Inc.
December 17, 2018
Page 2

       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, action or
absence of action by the staff.

       You may contact Isaac Esquivel, Staff Accountant, at (202) 551-3395 or
Daniel Gordon,
Senior Assistant Chief Accountant, at (202) 551-3486 with any questions.



                                                          Sincerely,
FirstName LastNameJohn A. Isakson
                                                          Division of
Corporation Finance
Comapany NamePreferred Apartment Communities, Inc.
                                                          Office of Real Estate
and
December 17, 2018 Page 2                                  Commodities
FirstName LastName