0000711642-08-000018.txt : 20120417 0000711642-08-000018.hdr.sgml : 20120417 20080307100049 ACCESSION NUMBER: 0000711642-08-000018 CONFORMED SUBMISSION TYPE: CORRESP PUBLIC DOCUMENT COUNT: 1 FILED AS OF DATE: 20080307 FILER: COMPANY DATA: COMPANY CONFORMED NAME: NATIONAL PROPERTY INVESTORS 4 CENTRAL INDEX KEY: 0000318508 STANDARD INDUSTRIAL CLASSIFICATION: REAL ESTATE [6500] IRS NUMBER: 133031722 STATE OF INCORPORATION: CA FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 1873 SOUTH BELLAIRE STREET STREET 2: 17TH FLOOR CITY: DENVER STATE: CO ZIP: 80222 BUSINESS PHONE: 3037578101 MAIL ADDRESS: STREET 1: 1873 SOUTH BELLAIRE STREET STREET 2: 17TH FLOOR CITY: DENVER STATE: CO ZIP: 80222 CORRESP 1 filename1.htm Letterhead

National Property Investors 4

55 Beattie Place, PO Box 1089

Greenville, SC 29602





March 7, 2008



Correspondence Filing Via Edgar and Overnight Delivery


Securities and Exchange Commission

Division of Corporation Finance

100 F Street N.E.

Washington, DC 20549


Attention:

Linda van Doorn

Mark Rakip

Re:

National Property Investors 4

Form 10-KSB for the fiscal year ended December 31, 2006 (File No. 000-10412)

Ladies and Gentlemen:

This letter responds to the comments raised by the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”) addressed to the undersigned on behalf of National Property Investors 4 (the “Partnership”) in a letter dated February 14, 2008 with respect to the above-referenced Form 10-KSB for the fiscal year ended December 31, 2006.  In connection with the response, the Partnership acknowledges that (a) the Partnership is responsible for the adequacy and accuracy of the disclosure in the filing; (b) Staff comments or changes to disclosure in response to Staff comments do not foreclose the Commission from taking any action with respect to the filing; and (c) the Partnership may not assert Staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.


General


1.

Comment:  We acknowledge your response to our prior comment from our letter dated January 24, 2008, and appreciate the greater clarity your proposed new disclosure provides.  In the event that the revolving credit facility is not terminated, you should include the audited balance sheet of the managing general partner in your future filings on Form 10-KSB.


The Partnership acknowledges that it will include, in response to the Staff’s comment, the disclosure proposed in the Partnership’s response letter dated February 1, 2008 in its next filing on Form 10-KSB. The Partnership further acknowledges that in the event the revolving credit facility is not terminated, the Partnership will include the audited balance sheet of the managing general partner in its future filings on Form 10-KSB.


Item 13. Exhibits


Exhibits 31.1 and 31.2


2.

Comment: Please amend your filing and include your certifications as exhibits to this Form 10-KSB.


The Form 10-KSB for the year ended December 31, 2006 has been amended to include the certifications as exhibits to this Form 10-KSB.  The amended document was filed on February 22, 2008.



If you need additional information, please contact Stephen B. Waters, Vice President, at (864) 239-1554 (phone) or (864) 239-5824 (facsimile).

 

Sincerely,

 

 

 /s/Stephen B. Waters

 

Stephen B. Waters

 

Vice President

 

NPI Equity Investments, Inc., Managing General Partner of National Property Investors 4