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                            August 8, 2023

       Paul Seavey
       Executive Vice President and Chief Financial Officer
       Equity Lifestyle Properties, Inc.
       Two North Riverside Plaza, Suite 800
       Chicago, IL 60606

                                                        Re: Equity Lifestyle
Properties, Inc.
                                                            Form 10-K for the
year ended December 31, 2022
                                                            Response dated July
7, 2023
                                                            File No. 001-11718

       Dear Paul Seavey:

              We have reviewed your July 7, 2023 response to our comment letter
and have the
       following comments. In some of our comments, we may ask you to provide
us with information
       so we may better understand your disclosure.

              Please respond to these comments 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 our
       comments apply to your facts and circumstances, please tell us why in
your response.

             After reviewing your response to these comments, we may have
additional
       comments. Unless we note otherwise, our references to prior comments are
to comments in our
       May 17, 2023 letter.

       Form 10-K for the year ended December 31, 2022

       Non-GAAP Financial Measures, page 47

   1.                                                   We note your response
to our comment 1. We refer you to your non-GAAP financial
                                                        measures Funds from
Operations, Normalized Funds from Operations, Property operating
                                                        revenues, excluding
deferrals, Income from property operations, excluding deferrals and
                                                        property management,
and Income from property operations, excluding deferrals. It
                                                        appears that such
non-GAAP measures accelerate the recognition of membership upgrade
                                                        revenues by recognizing
the entire amount of payments received as revenues in the current
                                                        period, as opposed to
recognizing the revenues over a 20 year period. Accelerating the
                                                        recognition of
membership upgrade sales appears to be inconsistent with Question 100.04
                                                        of the Non-GAAP C&DI.
Please revise your filing to remove this adjustment from your
                                                        non-GAAP measures, or
advise.
 Paul Seavey
Equity Lifestyle Properties, Inc.
August 8, 2023
Page 2
Consolidated Statements of Cash Flows, page F-9

2.       We note your response to comment 3. Please address the following:
             We note you concluded that there was a classification error in
prior periods due to
            the predominance principle discussed in ASC 230-10-45-22 through
22a not being
            applied appropriately in relation to the MH asset class. Please
clarify for us how you
            determined that this principle was not being applied appropriately
in prior periods.
            Your response should address, but not be limited to, (1) your
consideration of the
            information available to management at the time the MH asset cash
outflows were
            recorded within investing activities and (2) your consideration of
the level of
            management judgement necessary to apply this accounting literature.
             Please clarify for us how you determined that the predominant
source of cash flow
            comes from the proceeds of the sale of MHs. In your response,
please provide both
            qualitative and quantitative factors that went into your analysis.
Your response
            should address the consideration that you gave to the length of
time that the MHs will
            be rented out prior to sale. Additionally, to the extent you gave
more weight to
            quantitative factors, please tell us how you determined that was
appropriate and
            consistent with this accounting literature.
3.       We continue to consider your analysis of materiality that you provided
in your response to
         comment 3.
       You may contact Eric McPhee at 202-551-3693 or Jennifer Monick at
202-551-3295 with
any questions.



FirstName LastNamePaul Seavey                                 Sincerely,
Comapany NameEquity Lifestyle Properties, Inc.
                                                              Division of
Corporation Finance
August 8, 2023 Page 2                                         Office of Real
Estate & Construction
FirstName LastName