-----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, UmFzQO6fQ5r2suH1j8Hkrq2UYkT0t1WgPEAYykOb6ynb1P9UZ7Gq12sgeJqudhcD IA+uTTkCJs3S062UT6X4oA== 0000877860-08-000080.txt : 20081201 0000877860-08-000080.hdr.sgml : 20081201 20080929164323 ACCESSION NUMBER: 0000877860-08-000080 CONFORMED SUBMISSION TYPE: CORRESP PUBLIC DOCUMENT COUNT: 1 FILED AS OF DATE: 20080929 FILER: COMPANY DATA: COMPANY CONFORMED NAME: NATIONAL HEALTH INVESTORS INC CENTRAL INDEX KEY: 0000877860 STANDARD INDUSTRIAL CLASSIFICATION: REAL ESTATE INVESTMENT TRUSTS [6798] IRS NUMBER: 621470956 STATE OF INCORPORATION: MD FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 750-B SOUTH CHURCH STREET CITY: MURFREESBORO STATE: TN ZIP: 37130 BUSINESS PHONE: 6158909100 MAIL ADDRESS: STREET 1: P.O. BOX 1102 CITY: MURFREESBORO STATE: TN ZIP: 37133-1102 CORRESP 1 filename1.htm September 25, 2008



September 29, 2008



Kevin Woody, Accounting Branch Chief

Division of Corporation Finance

United States Securities and Exchange Commission

100 F. Street, N.E., Mail Stop 4561

Washington, D.C.  20549


Re:

National Health Investors, Inc.

Form 10-K for the year ended December 31, 2007

File No. 1-10822


Dear Mr. Woody:


This letter is offered in response to your letter, dated September 15, 2008, regarding the above referenced filing.  The Company’s response follows:


Item 2_ Properties Owned or Associated with Mortgage Loan Investments, page 14



1.

Staff Comment: “We note your response to comment 4 of our letter dated July 17, 2008.  We continue to believe that the requested schedule of lease expiration is material to investors.  Please confirm that you will include the requested disclosure in future filings.  Additionally, please revise Item 1 to describe your dependence on revenues received from NHC under the master lease, as required by item 101(c)(vii) of Regulation S-K.”


Response:


We confirm we will include in Item 2 in future filings a tabular schedule of lease expirations for each of the next 10 years disclosing the following:


·

the number of tenants whose leases will expire,

·

the total area or number of beds covered by such leases,

·

the annual rental represented by such leases, and

·

the percentage of gross annual rental represented by such leases.


With regard to disclosure required by item 101(c)(vii) of Regulation S-K it should noted that in paragraph 2 of Item 1, we currently name our major customer NHC and describe that of our investments in 124 Health Care Facilities, 41 are leased to NHC.  We also discuss the master lease and rental income received from NHC in Item 7 under the caption “Portfolio” and in Note 16 to the consolidated financial statements entitled “Relationship With National Healthcare Corporation.”


As requested above though, we will include further disclosure in Item 1 to describe our dependence on revenues received from NHC under the master lease.  Following the existing paragraphs in Item 1 under the caption “NHC Master Agreement to Lease” in which we describe the terms of the master lease, the rental income for the current year



and for the previous three years, and NHC’s responsibilities under the lease, we will insert the following sentence (with current information in parenthesis):  “Rental income from NHC in (2007) of ($33,700,000) was (66%) of our total rental income of ($51,005,000).”


In connection with responding to the Commission’s comments, the Company acknowledges the following:


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.


Should you wish to further discuss your comments and our responses thereto, please call me at 615-890-9100.


Sincerely,


NATIONAL HEALTH INVESTORS, INC.


/s/ Roger R. Hopkins



Roger R. Hopkins, CPA

Chief Accounting Officer



cc:  Kevin Woody, Accounting Branch Chief



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