SecProbe.io

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

       DIVISION OF
CORPORATION FINANCE

Mail Stop 7010

April 23, 2008

Via U.S. mail and facsimile

Mr. J. Larry Sorsby
Chief Financial Officer
Hovnanian Enterprises, Inc.
110 West Front Street, P.O. Box 500,
Red Bank, New Jersey 07701

 RE: Form 10-K for the year ended October 31, 2007
  Form 10-Q for the quarter ended January 31, 2008
   File No. 1-8551

Dear Mr. Sorsby:

  We have limited our review of the above  referenced reports to the matters listed
below.  If you disagree with a comment, we will consider your explanation as to why our
comment is inapplicable or a revision is unneces sary.  Please be as detailed as necessary
in your explanation.  In some of our comme nts, we may ask you to provide us with
supplemental information so we may better understand your disclosure.  After reviewing
this information, we may or may not 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.

FORM 10-K FOR THE YEAR  ENDED OCTOBER 31, 2007

General

1. Where a comment below requests additional disclosures or other revisions to be made, please show us in your supplemental response what the revisions will look like.  These revisions should be included in your future filings.

Mr. J. Larry Sorsby
April 23, 2008
Page 2 of 5
Management’s Discussion and Analysis, page 18

2. We note your discussion of the U.S. housing market and the impact that
developments in the homebuilding industr y and related mortgage finance industry
have had on your results of operations.  We urge you to find ways to provide
additional quantitative disclosures that conveys to investors the current and ongoing
risks related to the recoverabi lity of your homebuilding assets  as well as the risk that
additional charges may need to be record ed.  In addition, we  urge you to fully
consider the guidance in Release No. 33-8350.  In this regard, please note, in the
Critical Accounting Estimates section of the Release, the Staff’s view that companies
should provide quantitative disclosures when  quantitative information is reasonably
available and will provide material information for investors.  As a result, we caution you that, to the extent you gather and an alyze information regarding the risks of
recoverability of your homebuilding assets, such information may be required to be
disclosed if it would be mate rial and useful to investors.   For example, if you have
significant amounts of inventory for which you determine the fair value is close to
your book value, you should consider how you can constructively convey the potential risk associated with these in ventory amounts.  We believe that it is
important to provide investors with inform ation to help them evaluate the current
assumptions underlying your impairment asse ssment relative to your current market
conditions and your peers to enable them to attempt to assess the likelihood of
potential future impairments.  We believe that detailed rather th an general disclosures
regarding these risks and exposures would provide investors with the appropriate
information to make this evaluation.  Y ou should consider providing these additional
disclosures related to each type of poten tial charge, including impairment charges
related to inventories and intangible asse ts, write-off of additional deposits and pre-
acquisition costs related to land not being pursued, as well as charges related to
investments in joint ventures.  Please also consider whethe r these types of disclosures
would be more meaningful if provided at the segment level.

3. Your financial services operations consis t primarily of originating mortgages from
your homebuyers, selling such mortgages in the secondary market, and title insurance activities.  You note that the availability  of certain mortgage  financing products
became more constrained st arting in February 2007 when the mortgage industry
began to more closely scrutinize sub-prim e, Alt-A, and other non-prime mortgage
products.  Please expand your disclosures to address the risks and exposures to your
financial services operations related to th ese mortgage financing products, including
risks associated with bei ng able to resell these loan s.  Specifically, you should
disclose whether you originate any sub-prime, Alt-A, or other non-prime loans.  If so,
please disclose your definiti on and description of sub-prime and/or Alt-A loans as
well as your underwriting and risk management  policies related to these loans.  You
should also consider quantifying your exposure to each of these types of loans.

Mr. J. Larry Sorsby
April 23, 2008
Page 3 of 5
Critical Accounting Policies

Inventories, page 20

4. Please expand your critical accounting polic y to provide additi onal insight on how
you perform your impairment analysis under SFAS 144 for each inventory category reflected on your consolidated balance sheets.  Please consider including the
following:
• Please clarify how you determine which communities should be tested for
impairment as well as at what point in tim e they should be tested for impairment.
You state that for inventories of communities under development, a loss is recorded when events and circumstances indicate impairment and the undiscounted cash flows generated are less than the related carrying amounts.  Please expand your discussion to state the t ypes of events and circumstances that
you believe indicate impairment.  Plea se address whether you look for these
events and circumstances on a community  level as well as how frequently you
evaluate for these types of  events and circumstances;
• Please disclose the number of communities tested for impairment during each
period presented, the number of communities you determined to be impaired
during each period presented, and the tota l number of communities which exist at
the end of each period presented; and
• Please discuss the specific valuation met hods used to determine fair value for
each inventory category.  Please discuss th e significant estimates and assumptions
used to determine estimated future cash flows and fair value.  You should discuss how sensitive the fair value estimates are to each of these significant estimates
and assumptions used as well whether certa in estimates and assumptions are more
subjective than others.

Capital Resources and Liquidity, page 21

5. You provided for your cash requirements for the twelve months ended October 31, 2007 from housing and land sales, the revol ving credit facility, financial service
revenues, other revenues, distributions from joint ventures and tax refunds received in
fiscal 2007.  You believe that these sources  of cash are sufficient to finance your
working capital requirements and other n eeds.  We note that your homebuilding
revenues decreased by 22% or $1.3 billion from the year ended October 31, 2006 to
the year ended October 31, 2007.  In a ddition, the amount available under your
revolving credit line was reduced from $1.2 billion to $900 million in March 2008.  In light of the above, please discuss the si gnificant changes in these sources of cash
from period to period, the impact of th ese changes on your liquidity and capital
resources, and how you determined that these sources will still be sufficient.  You should also disclose if you expect any alte rnative sources of funding to be available.

Mr. J. Larry Sorsby
April 23, 2008
Page 4 of 5
6. We remind you that Item 303(A)(1) an (2) of Regulation S-K states that you should
discuss known trends or any known demands , commitments, events or uncertainties
that will result in or that are reasonably likel y to impact your liquid ity in any material
way as well as any material changes in the mix or relative co st of your capital
resources.  Given the trends and conditions  in the homebuilding and mortgage finance
industry which you have discussed else where, we urge you to expand your
disclosures to address the current and poten tial future impact of these trends and
conditions on your liquidity and capital resources.

7. As of October 31, 2007 and January 31, 2008, you disclose that you were not in
compliance with certain covenants under your Revolving Credit Agreement and that
you were able to obtain waivers of complia nce under these covenants.  Please discuss
the potential impact on your liquidity and cap ital resources of not being able to
comply with these covenants and obtain waivers of compliance in the future.  In addition, you disclosed that the borrowing ba se increases as in ventory increases.
Please clarify whether the borrowing base al so decreases as inve ntory decreases.
Given the amount available under your revol ving credit line was reduced from $1.2
billion to $900 million in March 2008, pleas e expand your disclosure to address the
risk that the amount availabl e under the revolving credit line could be subject to
further reductions.

8. The Revolving Credit Agreement contains events of default which would permit the lenders to accelerate the loans if not cure d within applicable grace periods, including
the failure to make timely payments under the agreement or other material
indebtedness, the failure to satisfy covena nts and specified events of bankruptcy and
insolvency.  Please clearly disclose which ev ents of default are most likely to occur
under the Revolving Credit Agreement as well as under any other debt agreements.  Given that you were not in compliance with the Consolidated  Tangible Net Worth
and Leverage Ratio covenants under the Revolving Credit Agreement and you state that you will likely violate one or more of this agreement’s covenants during 2008
based on your current expectations, pleas e provide a tabular presentation of the
required ratios as well as your actual ratios as  of each reporting da te.  This disclosure
should be provided for the Consolidated Tangible Net Worth and Leverage Ratio
covenants as well as for any additional  covenants which ar e material to an
understanding of your financial structure.  In a similar manner, please disclose the
required as well as your actual fixed charge coverage ratio as of the end of each
reporting period as defined in the indentur es governing your senior notes and senior
subordinated notes.

FORM 10-Q FOR THE QUARTER  ENDED JANUARY 31, 2008

General

9. Please address the above comments in your interim filings as well.

Mr. J. Larry Sorsby
April 23, 2008
Page 5 of 5
*    *    *    *

  Please respond to these comments with in 10 business days, or tell us when you
will provide us with a response.  Please pr ovide us with a supplemental response letter
that keys your responses to our comment s and provides any requested supplemental
information.  Detailed letters greatly facilitate our review.  Please file your supplemental
response on EDGAR as a correspondence file .  Please understand that we may have
additional comments after reviewin g your responses to our comments.

We urge all persons who are responsible for the accuracy and adequacy of the
disclosure in the filings reviewed by the staff to be certain that they have provided all information investors require for an info rmed decision.  Since the company and its
management are in possession of all facts re lating 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
• 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 regarding these comments, please direct them to Nudrat
Salik, Staff Accountant, at ( 202) 551-3692 or, in her absen ce, the undersigned at (202)
551-3689.

       S i n c e r e l y ,

       John Hartz
       Senior Assistant Chief Accountant