SecProbe.io

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                                December 20, 2004

VIA EDGAR AND COURIER
---------------------

John Cash
Accounting Branch Chief
United States Securities and Exchange Commission
Division of Corporation Finance
450 Fifth Street, NW
Mail Stop 4-4
Washington, D.C. 20549-0404

         Re:      Orleans Homebuilders, Inc. (the "Company")
                  Form 10-K for FYE June 30, 2004, filed August 26, 2004

Dear Mr. Cash:

         This letter responds to the comments in your letter to the Company,
dated December 7, 2004. The comments in your letter relate to the Company's
Annual Report on Form 10-K for the fiscal year ended June 30, 2004.

Form 10-K for the Year Ended June 30, 2004
------------------------------------------

MD&A - New Orders and Backlog

     1.  We note your response to our previous comment 1. We read that
         cancellations as a percentage of gross new orders have been fairly
         consistent over the past few years (13%, 11% and 15%) and that you have
         been able to quickly resell all cancelled homes at prices above the
         original sales price. However, given the volatility of the housing
         market and the importance of backlog as a predictor of future results,
         we believe that it is important to provide your readers with insight
         into the potential risk represented by ongoing cancellations of new
         orders. To provide increased transparency into your business, and to
         help your readers view your company through the eyes of management, in
         future filings, please disclose the cancellation rates for the last
         three fiscal years. We will not object to you also disclosing that thus
         far you have been able to quickly resell all cancelled homes at prices
         above the original sales price.

         RESPONSE: The Company will disclose in future filings on Form 10-K the
         cancellation rates of new orders for the preceding three fiscal years.

     2.  We note from your response to our previous comment 1 that you
         anticipate that approximately 6% to 7% of the contracts included in the
         backlog at June 30, 2004 will be cancelled prior to settlement. This
         cancellation rate seems unusually low given historical cancellations
         rates of the past three fiscal years of 11% to 15%. Please provide us a
         more detailed explanation of why you anticipate such a low cancellation
         rate for the June 30, 2004 backlog. In future filings, if you have a
         significant increase or decrease in your cancellation rates, such as
         this appears to be, please discuss the impact of the change on
         cancellations on backlog.

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John Cash
December 20, 2004
Page 2

         RESPONSE: The Company does not anticipate a significant increase or
         decrease in the cancellation rate of new orders for the fiscal year
         ending June 30, 2005 from the cancellation rate of new orders over the
         previous three fiscal years. However, the Company expects a low
         cancellation rate as it applies to the June 30, 2004 backlog, as some
         previous months' cancellations have already taken place and are no
         longer in backlog. For example, the new orders in the backlog at June
         30, 2004 that are expected to be delivered in July 2004 have a
         significantly lower cancellation probability than the new orders in the
         backlog at June 30, 2004 that are expected to be delivered in December
         2004. Given the aforementioned, the Company applies a probability of
         cancellation to the orders in backlog, based on the month each order
         was received. Based on this calculation, it was determined that the
         cancellation rate of the new orders in backlog at June 30, 2004 will be
         less than the historical cancellation rate of new orders.

         As noted in the response to comment 1, the Company will disclose in
         future filings on Form 10-K the cancellation rate of new orders for the
         preceding three fiscal years. Additionally, the Company will discuss in
         future filings on Form 10-K any significant increases or decreases in
         the cancellation rates of new orders.

Closing Comments
----------------

         The Company believes that the above fully responds to your questions
and comments. If you have any additional questions or comments, please contact
me at you earliest convenience. Thank you very much.

                                        Sincerely,

                                        Joseph A. Santangelo
                                        Treasurer and Chief Financial Officer

Enclosures

cc:  Nathan Cheney
     Jennifer Thompson

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