SecProbe.io

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-7010

       DIVISION OF
CORPORATION FINANCE

Mail Stop 7010

April 20, 2006

Mr. J. Larry Sorsby
Executive Vice President and Chief Financial Officer
Hovnanian Enterprises, Inc.
10 Highway 35, P.O. Box 500
Red Bank, New Jersey 07701

 RE:  Form 10-K for the Fisc al Year ended October 31, 2005
  Form 10-Q for the Quar ter ended January 31, 2006
                     File No. 1-8551

Dear Mr. Sorsby:

  We have reviewed these filings a nd have the following comments.  If you
disagree with a comment, we will consider your explanation as to why our comment is
inapplicable or a revision is unnecessary.  Pl ease be as detailed as necessary in your
explanation.  In some of our comments, we may ask you to provide us with information
so we may better understand your disclosure.  After reviewing this information, we may
raise additional comments.

 Please understand that the purpose of our re view process is to assist you in your
compliance with the applicable disclosure  requirements and to  enhance the overall
disclosure in your filing.  We look forward to  working with you in these respects.  We
welcome any questions you may have about our comments or on any other aspect of our review.  Feel free to call us at the telephone numbers listed at the end of this letter.

J. Larry Sorsby
Hovnanian Enterprises, Inc.
April 20, 2006 Page 2 of 6
Form 10-K for the year ended October 31, 2005

General
1. Where a comment below requests additional disclosures or other revisions to be made, please show us in your response wh at the revisions will look like.  These
revisions should be included in your future  filings, including your interim filings
where applicable.

Residential Development Activities, page 7
2. You disclosed that the number of new ho mes sales contracted slightly in the
West Region due to the timing of the ope ning of new communities in 2005.  In
future filings, please provide more detail and explain how the timing of opening new communities in 2005 differs from that  of the prior year. We also note the
reduction in homes delivered, net contract s signed and contract backlog in your
West Region that occurred subsequent to year-end as disclosed in the Form 10-Q
report for the first quarter of 2006. If the lower sales are due to multiple factors,
including overall market f actors, you should expand these types of discussions in
future filings.

Management’s Discussion and Analysis of Fi nancial Condition and Results of Operations

Results of Operations, page 17
3.  If material in future filings, please provide a comprehensive discussion on the number of cancellations of home sales contracts by region and in total and
discuss trends in the level of home sales cancellations in relation to historical
levels.  Please refer to Item  303 (3) of Regulation S-K.

Financial Statements

Consolidated Balance Sheet, page F-3
4. In future filings, please present restricted  cash held in escrow separately on the
face of the balance sheet.  Please refer to Rule 5-02 of Regulation S-X.

Consolidated Statements of Cash Flows, page F-7
5. In future filings, do not include restri cted cash in the cash total in your
statements of cash flows.  Please refe r to rule 5-02 of Regulation S-X.
6. Given the various acquisitions of homebuild ers in recent years, in future filings
please disclose separately the amounts pa id to acquire homebuilding companies

J. Larry Sorsby
Hovnanian Enterprises, Inc.
April 20, 2006 Page 3 of 6
and the amounts paid to purchase property, equipment and other fixed assets in
net cash used in investing activit ies.  Please refer to SFAS 95.
7. You disclosed that investments in unconsolidated homebuilding and land
development joint ventures totaled over  $1.1 billion in 2005 and that they had
increased from $212 million in the prior year  in footnote 18.  In future filings,
please disclose separately the cash fl ows associated with investments in
unconsolidated subsidiaries and cash flow s associated with distributions of
capital from unconsolidated subsidiaries  in your statements of cash flows.
Please refer to SFAS 95.

Note 1.  Basis of Presentation and Segment Information, page F-8
8. We note significant regional informa tion in both your Business section and
MD&A. Please provide a comprehensive analysis explaining how you have
defined your reportable segments. For ex ample, we assume that your operating
segments are at a lower level for pur poses of managing your business and that
you have aggregated certain operating se gments. We may have further comment.
9. In future filings, please disclose your accounting policy and th e factors that you
consider in determining whether or not to consolidate joint ventures where you
are the manager of the joint venture.
10. In future filings, please provide enterp rise-wide product-line disclosures for each
group of similar product as required by paragraph 37 of SFAS 131.  This
disclosure should include revenues from  the single-family detached homes,
attached townhouses and condominiums, mid-rise and high-rise condominiums
and planned residential developments described under Business Overview.
Paragraph 101 of SFAS 131 states that  enterprise-wide disclosures are
appropriate for all enterprise s if a range of products a nd services are offered.

Note 2.  Summary of Significant Accounting Policies, page F-8
11. In future filings, disclose your revenue recognition policy for attached condominiums, townhouses and mid-to-high- rise condominiums.  Please refer to
SFAS 66.
12. In future filings, please disclose sepa rately the allowance for doubtful accounts
and notes receivable either in the balan ce sheet, the footnotes to the financial
statements or in the Valuation and Qu alifying Accounts Sche dule in accordance
with Rules 5-02 and 5-04 of Regulation S-X.

J. Larry Sorsby
Hovnanian Enterprises, Inc.
April 20, 2006 Page 4 of 6
Insurance Deductible Reserves, page F-9
13. You disclosed that you increased signifi cantly your general liability insurance
and workers compensation deductibles pe r occurrence in 200 5 and that in 2006
the deductibles per occurrence will increase further to $20 million for bodily injury and property damage, $20 million for product defects and $1 million for
worker’s compensation.  You also disc losed that you introduced an insurance
program to your subcontractors where by they will pay you insurance premiums
and you will assume the liab ility associated with wo rk they perform on your
homes.  Given the increasing risks that  you are self-insuring and your exposure
to loss under your recently introduced insurance program for your subcontractors, please disclose the following:

• Your basis for estimating unpaid claims, claim adjustment expenses and
incurred but not reported claims reserv es for the various risks that you are
assuming.  Please also disclose
if these insurance reserves include provisions fo r inflation, claims handling,
other administrative expens es and legal fees.
• The amount of insurance claims pa id over the last three years.
• Your revenue recognition policy under the insurance program that you offer
your subcontractors.  Please also tell us how you are classifying the income earned from your insurance program in your income statement.

Intangible Assets, page F-10
14. You disclosed that in May 2004 you change d the brand name of a real estate
company acquired in 2002 to K.  Hovnanian  Homes.  Due to the change in the
brand name you reclassified $50 milli on from goodwill and indefinite life
intangible assets to definite life inta ngible assets that you are amortizing over
more than four years.  Please explain in more detail the following:

• Why the original brand name was classifi ed as an indefinite life intangible;
• Why the name change would result in a reclassification of goodwill to definite
life intangibles;
• Provide support for the real ization of the definite lif e intangible related to the
previous brand.

Accounting for Derivative Instrument s and Hedging Activities, page F-12
15. Under Customer Financing you disclosed that you sell mortgage loans in pools or individually and against forward commit ments to institutional investors.  In
future filings, expand n footnote 6 to desc ribe the methods and assumptions used
to estimate their fair value, any associat ed hedging strategies and the net gains or

J. Larry Sorsby
Hovnanian Enterprises, Inc.
April 20, 2006 Page 5 of 6
losses recognized in earnings during the period.  Please refer to SFAS 133,
SFAS 149 and SAB Topic 5DD.

Note 17.  Variable Intere st Entities, page F-21
16. We note that most of your cas h and letters of credit to  purchase land and lots are
not consolidated. We assume this is b ecause you either do not consider them to
be VIEs, and/or you do not consider yourse lf to be the primary beneficiary.
Please expand your disclosures to provide an overall understanding as to how you interpret an option for land or lots to be a VIE.  Fo r example, disclose what
you consider to be a significant nonrefundable option fee, and how that impacts your interpretation. Also expand you disclo sures to explain the conditions under
which you are not considered the primary beneficiary, both in technical terms
and how the nature of the option econom ically results in that determination.
Please refer to FIN 46 (R).

*    *    *    *

        Please respond to these comments within 10 business days, or tell us when you will provide us with a response.  Please provi de us with a response letter that keys your
responses to our comments and provides a ny requested information.  Detailed letters
greatly facilitate our review .  Please file your response on EDGAR as a correspondence
file.  Please understand that we may have additional comments after reviewing your
responses to our comments.

       We urge all persons who are res ponsible for the accuracy and adequacy of the
disclosure in the filings reviewed by the staff to be certain that they have provided all information required under the Securities Ex change Act of 1934 and that they have
provided all information investors require fo r an informed decision.  Since the company
and its management are in possession of all f acts relating to a company’s disclosure, they
are responsible for the accuracy and adequacy  of the disclosures they have made.

  In connection with responding to our comments, please provide, in writing, a
statement from the company acknowledging that:

• the company is responsible for the adequacy  and accuracy of the disclosure in their
filings;

• staff comments or changes to disclosure  in response to staff comments do not
foreclose the Commission from taking any action with respect to the filing; and

J. Larry Sorsby
Hovnanian Enterprises, Inc.
April 20, 2006 Page 6 of 6

• 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 United States.

  In addition, please be advi sed that the Division of En forcement has access to all
information you provide to the staff of the Divi sion of Corporation Fi nance in our review
of your filing or in response to our comments on your filing.

        If you have any questions regardi ng these comments, please direct them to Gus
Rodriguez, Staff Accountant, at (202) 551-3752 or, in his absence, to the undersigned, at
(202) 551-3689.

         Sincerely,

            John Hartz
                                                            Senior Assistant Chief Accountant