CPTCamden Property Trust

Summary of Significant Accounting Policies and Recent Accounting Pronouncements Income Recognition, page F-12 1. We note your disclosure that your rental revenue is recorded when due from residents and is recognized monthly as it is earned. To the extent you have non-level rents, please tell us and revise future filings to clarify if you record rental revenue on a straight-line basis. Please refer to ASC 840-20-25.

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Exhibit 99.1 2. We note your presentation of FFO per share and AFFO per share for the three and six months ended June 30, 2018 and 2017. In future earnings releases, please reconcile these non-GAAP per share measures to GAAP earnings per share. Please refer to Question 102.05 of the updated Compliance and Disclosure Interpretations issued on May 17, 2016.

The amount of lease concessions recognized during fiscal years 2017, 2016, and 2015 was approximately $4.7 million, $3.7 million, and $2.8 million, respectively, and was recognized over the life of the applicable leases in accordance with ASC 840-20-25. We will modify the first sentence of “Income Recognition” on page F-12 in future filings, as appropriate, as follows:

“Our rental revenue is recognized on a straight-line basis and other property revenue is recorded when due from residents and is recognized as it is earned.”

Camden Property Trust

11 Greenway Plaza, Suite 2400 Houston, TX

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77046 P 713 354 2500 F 713 354 2700

Exhibit 99.1

2. We note your presentation of FFO per share and AFFO per share for the three and six months ended June 30, 2018 and 2017. In future earnings releases, please reconcile these non-GAAP per share measures to GAAP earnings per share. Please refer to Question 102.05 of the updated Compliance and Disclosure Interpretations issued on May 17, 2016.

We will revise our presentation in future filings similar to the presentation below:

Three Months Ended June 30,

Six Months Ended June 30,

2018

2017

Total earnings per common share - diluted

$

0.40

0.43

0.81

0.82

Real estate depreciation and amortization

0.76

0.69

1.47

1.36

Adjustments for unconsolidated joint ventures

0.02

0.05

Income allocated to non-controlling interests

0.01

FFO per common share - Diluted

1.19

1.15

2.34

2.24

Recurring capitalized expenditures

(0.19

)

(0.18

(0.30

(0.29

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We note that your reconciliation to FFO attributable to common shareholders and Adjusted FFO attributable to common shareholders begins with Net income attributable to common shareholders, however the reconciliation adds back income allocated to noncontrolling interests. It appears that your FFO and AFFO measures represent FFO and AFFO on a company-wide basis.

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Please advise and revise your presentation in future filings to either remove the “income allocated to non-controlling interests” adjustment from the calculation of FFO or rename the FFO and AFFO measures to remove the phrase “attributable to common shareholders.”

We started the reconciliation with net income attributable to common shareholders with the intent to provide FFO on a Company-wide basis. We will revise our presentation in future filings and rename the FFO and AFFO measures to remove the phrase "attributable to common shareholders" similar to the presentation below:

Camden Property Trust

11 Greenway Plaza, Suite 2400 Houston, TX 77046 P 713 354 2500 F 713 354 2700

Reconciliations of net income attributable to common shareholders to FFO and AFFO for the three months ended March 31, 2016 and 2015 are as follows:

Three Months Ended

March

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31,

($ in thousands)

2016

2015

Funds from operations

Net income attributable to common shareholders (1)

$

41,730

115,599

Real estate depreciation and amortization, including discontinued operations

64,812

60,363

Adjustments for unconsolidated joint ventures

2,358

2,245

Gain on sale of operating properties, net of tax

-

(85,145

)

Income allocated to non-controlling interests

1,210

5,466

110,110

98,528

Less: recurring capitalized expenditures

(9,294

(10,644

Adjusted funds from operations

100,816

87,884

Weighted average shares - basic

89,344

88,987

Incremental shares issuable from assumed conversion of:

Common share options and awards granted

355

391

Common units

1,894

1,897

Weighted average shares - diluted

91,593

91,275

(1)

Net income attributable to common shareholders for the three months ended March 31, 2016 includes a gain on sale of $0.4 million related to the sale of one land holding.

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Summary of Significant Accounting Policies and Recent Accounting Pronouncements, page 9 2. We note that two of your consolidated operating partnerships are VIEs in which you are considered the primary beneficiary. In future filings please include the disclosures outlined in ASC 810-10-50-3. Within your response, provide an example of your intended disclosure.

As disclosed in Footnote 2 on page F-13 of our Form 10-K for the fiscal year ended December 31, 2015, we adopted Accounting Standards Update 2015-02 ("ASU 2015-02"), Amendments to the Consolidation Analysis, on January 1, 2016. Within Footnote 2, we indicate our two operating partnerships would continue to be consolidated within our financial statements, and refer to Footnote 5, "Operating Partnership." The Company owns 92.2% of the limited partner interests of Camden Operating, L.P. and 94.2% of the limited partner interests of Camden Summit Partnership, L.P.

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(collectively, the "Partnerships"); the Company also owns 100% of the general partner interests of the Partnerships.

The Company did not provide the VIE presentation requirements of ASC 810-10-50-3 due to the application of the disclosure exemption criterion in ASC 810-10-50-5B as the general partner's interest should be considered a "majority voting interest" as the general partner:

(a)

Holds an equity investment that is more than inconsequential; we believe owning 100% of the general partner interests and over 90% of the limited partner interests of the Partnerships is considered more than inconsequential.

(b)

Has the power to direct the activities of the VIE that most significantly affect the VIE's economics through its equity interest, which would generally be the case when there are no kick-out rights held by the limited partners; the limited partner interests of the Partnerships not owned by the Company do not have the ability to direct the activities of the Partnerships, nor do they have the ability to remove the Company as the general partner of the Partnerships.

Additionally, the VIE's assets can be used for purposes other than the settlement of the VIE's obligations and the VIEs meet the definition of a business.

We believe as the above conditions have been met, the general partner holds 100% of the voting class of the Partnerships and the Company is exempt from providing the disclosures in ASC 810-10-50-3.

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We note that you discuss property revenues, property expenses and property net operating income on a same store basis, which appear to be non-GAAP presentations. Please explain to us how your disclosure provides all of the information required by Item 10(e) of Regulation S-K.

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Specifically, management should disclose the reasons they believe the non-GAAP measure provides useful information to investors and the additional purposes, if any, for which management uses the non-GAAP measure.

We believe the same store presentation beginning on page 27 of our Form 10-Q for the quarterly period ended March 31, 2016, provides all of the information required by Item 10(e) of Regulation S-K. The Company provided a reconciliation of net income to net operating income (“NOI”) for the three months ended March 31, 2016 and 2015. This reconciliation was followed by an additional detail of the components of NOI between same store communities, non-same store communities, development and lease-up communities, and dispositions/other.

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We will continue to provide a reconciliation of net income to NOI and will specifically label same-store NOI as a non-GAAP measure in future filings.

Same store communities in our March 31, 2016 Form 10-Q represented stabilized communities as of January 1, 2015. Management believes same-store information is useful as it allows both management and investors to determine financial results over a particular period for the same set of communities. The other property groups are also useful to investors as it provides results attributable to new or disposed of communities. We will add the additional clarification management believes same-store information is useful as it allows both management and investors to determine financial results over a particular period for the same set of communities in future filings within the footnote relating to “Same Store” currently provided under the property NOI table disclosed on page 29.

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We note your definition of EBITDA. Please note that measures calculated differently from EBITDA (as described in Exchange Act Release No. 47226) should not be characterized as EBITDA and their titles should be distinguished from EBITDA, such as Adjusted EBITDA. Reference is also made to Question 103.01 of the Compliance and Disclosure Interpretations on Non-GAAP Financial Measures.

We note your references related to EBITDA and non-GAAP Financial Measures and will incorporate similar disclosures, such as Adjusted EBITDA, in future filings as appropriate.

We acknowledge:

• the Company is responsible for the adequacy and accuracy of the disclosure in the filing;

staff comments or changes to disclose 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

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United States.

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