United States securities and exchange commission logo
May 29, 2024
Robert A. Garechana
Executive Vice President and Chief Financial Officer
Equity Residential
Two North Riverside Plaza
Chicago, Illinois 60606
Re: Equity Residential
ERP Operating
Limited Partnership
Form 10-K for the
fiscal year ended December 31, 2023
Filed February 15,
2024
File No. 001-12252
File No. 000-24920
Dear Robert A. Garechana:
We have limited our review of your filing to the financial
statements and related
disclosures and have the following comment.
Please respond to this letter 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 a
comment applies to your facts and circumstances, please tell us why in
your response.
After reviewing your
response to this letter, we may have additional comments.
Form 10-K for fiscal year ended December 31, 2023
Item 8. Financial Statements and Supplementary Data
Consolidated Financial Statements
Notes to Consolidated Financial Statements
17. Reportable Segments, page F-56
1. We note you do not
appear to provide a reconciliation for your segment measure of profit
or loss of Net
operating income. In future periodic filings, including your subsequent
interim Form 10-Q
filings, please provide a reconciliation to reconcile your segment
measure to Net (loss)
income before income tax. Refer to ASC 280-10-50-30b.
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.
Robert A. Garechana
Equity Residential
May 29, 2024
Page 2
Please contact Peter McPhun at 202-551-3581 or Mark Rakip at
202-551-3573 with any
questions.
FirstName LastNameRobert A. Garechana Sincerely,
Comapany NameEquity Residential
Division of Corporation
Finance
May 29, 2024 Page 2 Office of Real Estate &
Construction
FirstName LastName