MAAMid-America Apartment Communities

We note that you currently have five properties in development and that you completed one development during the year ended December 31, 2023. In future Exchange Act periodic reports, for each completed development, please disclose the total cost incurred, the development costs per unit, and clarify whether those development costs include leasing costs. Item 2.

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Properties, page 27 We note your disclosure on page 31 that you believe average effective rent is a helpful measure. Please tell us and revise the table in future filings to disclose your base rent per unit and average effective annual rent per unit, taking into account the impact of free rent, tenant reimbursements, and tenant concessions. We also note that you have 34 apartment communities with a retail component. Please provide separate disclosure regarding your 2. retail assets, addressing occupancy levels, base rent per square foot, and average effective rent per square foot. 3. In future Exchange Act periodic reports, please discuss leasing results for the prior period, including the amount of leases that were new leases compared to renewal leases. Additionally, this disclosure should include discussion of tenant improvement costs, leasing commissions, and tenant concessions. Please provide separate disclosure regarding your retail assets and provide disclosure for these assets on a per square foot basis.

Mid-America Apartment Communities, Inc. (“MAA”) acknowledges receipt on July 30, 2024 of the Staff’s letter dated July 30, 2024 (the “July 30, 2024 Comment Letter”) containing comments on the above-captioned filing. The July 30, 2024 Comment Letter requests a response within 10 business days. The Finance and Accounting team that is primarily responsible for responding were working on preparing MAA’s

Quarterly Report on Form 10-Q for our fiscal quarter ended June 30, 2024 for part of the response period.

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In addition, MAA has multiple key parties that are out of the office during the original

10-day response period. Accordingly, we respectfully request an extension of the response period for an additional 14 business days until September 3, 2024.

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Based on footnote (1), it appears that interest expense related to variable-rate debt that is not subject to an interest rate swap agreement is not included. To the extent material, please revise your disclosures in future periodic reports to discuss the cash requirements for such variable-rate debt. Reference is made to footnote 46 of SEC Interpretive Release

Based on footnote (1), it appears that interest expense related to variable-rate debt that is not subject to an interest rate swap agreement is not included. To the extent material, please revise your disclosures in future periodic reports to discuss the cash requirements for such variable-rate debt. Reference is made to footnote 46 of SEC Interpretive Release 33-8350 “Interpretation: Commission Guidance Regarding Management's Discussion and Analysis of Financial Condition and Results of Operations.”

The Company acknowledges the Staff’s comment and advises the Staff that the Company will

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revise its disclosures in future periodic reports, to the extent material, to discuss the cash requirements for interest related to variable-rate debt that is not subject to an interest rate swap agreement.

We hope that this response satisfactorily addresses the Staff’s comment. If you have any further comments or questions or require any additional information concerning the matters discussed herein, please contact me at (901) 248-4169.

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We note your disclosure on page 34 that results for the three months ended March 31, 2017 included $29.3 million of additional depreciation and amortization expense related to the step-up in asset values from the Post Properties Merger. Please clarify what is meant by the step-up in asset values, and how it generated additional depreciation compared to your prior year.

The Company acknowledges the Staff’s comment and advises the Staff that the wording “step-up in asset values from the Post Properties Merger” was intended to be synonymous with “increase in assets as a result of the Post Properties Merger.” The Company further advises the Staff that in addition to acquiring a substantial new portfolio of assets in the Post Properties Merger, the values of those assets were adjusted to their estimated fair values as of December 1, 2016 (the acquisition date), in accordance with FASB Accounting Standards Codification 805, Business Combinations.

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As a result of the increase in the

Company’s assets due to the Post Properties Merger, the amount of depreciation and amortization expenses recognized by the Company also increased as compared to the prior year period. To the extent applicable, in future filings, the Company will clarify that the additional depreciation and amortization expense was a result of the Post Properties Merger.

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We note that your calculation of EBITDA on page 12 contains adjustments for items other than interest, taxes, depreciation and amortization. Please revise future earnings releases to ensure that measures calculated differently from EBITDA are not characterized as EBITDA. See Question 103.01 of the updated Compliance and Disclosure Interpretations issued on May 17, 2016.

The Company acknowledges the Staff’s comment and advises the Staff that in future earnings releases, measures calculated differently from EBITDA will not be characterized as EBITDA.

We hope that this response satisfactorily addresses the Staff’s comments. If you have any further comments or questions or require any additional information concerning the matters discussed herein, please contact me at 901-248-4169. Read in the reply ↗