June 16, 2025 H. Lynn C. Stanfield Chief Financial Officer Apartment Investment and Management Company 4582 South Ulster Street, Suite 1450 Denver, CO 80237 Re: Apartment Investment and Management Company Form 10-K for the year ended December 31, 2024 Form 8-K filed February 24, 2025 File No. 001-13232 Dear H. Lynn C. Stanfield: We have completed our review of your filings. 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. Sincerely, Division of Corporation Finance Office of Real Estate & Construction