-----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, RQQ6XT4mhzkD0IGVkkR0fi94NDy19X5kO3HnvU4fyLBFPMRK5xG76t3qb9xxh+QI SzqK3f8Ean+bvsAb0iEX9A== 0000000000-05-019335.txt : 20060807 0000000000-05-019335.hdr.sgml : 20060807 20050420140728 ACCESSION NUMBER: 0000000000-05-019335 CONFORMED SUBMISSION TYPE: UPLOAD PUBLIC DOCUMENT COUNT: 1 FILED AS OF DATE: 20050420 FILED FOR: COMPANY DATA: COMPANY CONFORMED NAME: REAL ESTATE ASSOCIATES LTD VI CENTRAL INDEX KEY: 0000715578 STANDARD INDUSTRIAL CLASSIFICATION: REAL ESTATE [6500] IRS NUMBER: 953778627 STATE OF INCORPORATION: CA FISCAL YEAR END: 1229 FILING VALUES: FORM TYPE: UPLOAD BUSINESS ADDRESS: STREET 1: 9090 WILSHIRE BLVD STE 201 CITY: BEVERLY HILLS STATE: CA ZIP: 90211 BUSINESS PHONE: 3102782191 MAIL ADDRESS: STREET 1: 9090 WILSHIRE BLVD SUITE 201 CITY: BEVERLY HILLS STATE: CA ZIP: 90211 LETTER 1 filename1.txt April 20, 2005 Mail Stop 0409 VIA U.S. MAIL AND FAX (864) 239-5824 Brian H. Shuman Chief Financial Officer Real Estate Associates Limited VI 55 Beattie Place P.O. Box 1089 Greenville, SC 29602 Re: Real Estate Associates Limited VI Form 10-KSB for the year ended December 31, 2004 File No. 0-13112 Dear Mr. Shuman: We have reviewed the above referenced filing and have the following comments. We have limited our review to only your financial statements and related disclosures and will make no further review of your documents. As such, all persons who are responsible for the adequacy and accuracy of the disclosure are urged to be certain that they have included all information required pursuant to the Securities Exchange Act of 1934. Where indicated, we think you should revise your documents in response to these comments. If you disagree, we will consider your explanation as to why our comment is inapplicable or a revision is unnecessary. Please be as detailed as necessary in your explanation. In some of our comments, we may ask you to provide us with supplemental information so we may better understand your disclosure. After reviewing this information, we may or may not raise 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 on 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 Note 1 - Organization and Summary of Significant Accounting Policies Principles of Consolidation 1. Please confirm to us that you are consolidating Real Estate Limited Associates III (REA III). Also, tell us the percentage ownership of REA III and your basis for consolidation. Recent Accounting Pronouncements 2. We note that you adopted FIN 46(R) and you determined that you held variable interests in 15 VIE`s for which the Partnership was not the primary beneficiary. Please tell us how you determined that the interests the company holds in the partnerships are variable interests. In addition, please tell us how you determined that you were not considered the primary beneficiary considering that you own 95 to 99% of the local limited partnerships. Reference is made to paragraphs 14 - 17 of FIN 46(R). * * * * We urge all persons who are responsible for the accuracy and adequacy of the disclosure in the filing reviewed by the staff to be certain that they have provided all information investors require for an informed decision. Since the company and its management are in possession of all facts relating to a company`s disclosure, they are responsible for the accuracy and adequacy of the disclosures they have made. In connection with responding to our comments, please provide, in writing, a statement from the company acknowledging that: * the company is responsible for the adequacy and accuracy of the disclosure in the filing; * 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 * the company 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. In addition, please be advised that the Division of Enforcement has access to all information you provide to the staff of the Division of Corporation Finance in our review of your filing or in response to our comments on your filing. As appropriate, please respond to these comments within 10 business days or tell us when you will provide us with a response. Please furnish a cover letter with your amendment that keys your responses to our comments and provides any requested supplemental information. Detailed cover letters greatly facilitate our review. Please file your cover letter on EDGAR. Please understand that we may have additional comments after reviewing your responses to our comments. You may contact James Webster, Staff Accountant, at (202) 824- 5574 or me, at (202) 942-2813 if you have questions. Sincerely, Daniel Gordon Accounting Branch Chief ?? ?? ?? ?? Real Estate Associates Limited VI April 20, 2005 3 -----END PRIVACY-ENHANCED MESSAGE-----