Mailstop 3233 September 19, 2018 Via E-mail Mr. Thomas E. O'Hern Senior Executive Vice President and Chief Financial Officer The Macerich Company 401 Wilshire Boulevard, Suite 700 Santa Monica, California 90401 Re: The Macerich Company Form 10-K Filed February 23, 2018 File No. 001-12504 Dear Mr. O'Hern: We have limited our review of your filing to the financial statements and related disclosures 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. Item 7. Management's Discussion and Analysis of Financial Condition and Results of Operations Management's Overview and Summary, page 42 Comparison of years ended December 31, 2017 and 2016, page 50 1. We note that you recognized $18.1m and $19.2m in lease termination income in 2017 and 2016 respectively. We further note your disclosure on page 17 that a number of your tenants have declared bankruptcy in recent years. Please tell us what consideration you have given to discussing recent tenant bankruptcies and the impact of those bankruptcies on current and future operations in your MD&A. Mr. Thomas E. O'Hern The Macerich Company September 19, 2018 Page 2 Financial Statements 11. Co-Venture Arrangement, page 93 2. Please explain to us in greater detail why the adoption of ASC 606 resulted in a change in the accounting for the joint venture holding Freehold Raceway Mall and Chandler Fashion Center. Cite any relevant accounting guidance in your response. 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. You may contact Peter McPhun at 202-551-3581 or me at 202-551-3438 with any questions. Sincerely, /s/ Robert F. Telewicz, Jr. Robert F. Telewicz Jr. Branch Chief Office of Real Estate and Commodities