SecProbe.io

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

       DIVISION OF
CORPORATION FINANCE

  Mail Stop 7010
April 10, 2009
 Via U.S. mail and facsimile

 Mr. Ara K. Hovnanian President and Chief Executive Officer Hovnanian Enterprises, Inc.
110 West Front Street
P.O. Box 500 Red Bank, NJ  07701
 RE: Form 10-K for the fiscal  year ended Oc tober 31, 2008
  Form 10-Q for the fiscal  period ended January 31, 2009
File No. 001-08551

Dear Mr. Hovnanian:    We have reviewed your response letter  dated March 25, 2009 and have the following
additional comments.  If you disagree with any comments, we will consider your explanation as to why the comment is inapplicable or a revisi on is unnecessary.  Please be as detailed as
necessary in your explanation.     Please understand that the purpose of our re view process is to assist you in your
compliance with the applicable disclosure requir ements 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 aspe ct of our review.  Feel free to call us at
the telephone numbers listed at  the end of this letter.

FORM 10-K FOR THE FISCAL YEAR ENDED OCTOBER 31, 2008

General

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

Mr. Ara K. Hovnanian
April 10, 2009
Page 2    Consolidated Financial Statements

 Note 8 – Mortgages and No tes Payable, page F-18

 2. We note your response to comment 2 from our le tter dated March 9, 2009.  In future filings
where your calculation of the fixed charge cove rage ratio exceeds at least 2.0 to 1.0 but there
is a reasonably possible chance that you will be restricted from paying dividends, making
distributions on common and preferred stock, making certain investments or repurchasing
debt or equity, please revise to  disclose your actual fixed ch arge coverage ratio with any
necessary reconciliation to U.S. GAAP.

FORM 10-Q FOR THE PERI OD ENDED JANUARY  31, 2009

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

 Capital Resources and Liquidity

 3. It appears that three ratings agencies downgraded your cr edit ratings between March 4, 2009
and March 16, 2009.  At least two of these dow ngrades occurred after January 31, 2009 but
prior to the filing of your Form 10-Q.  It  is unclear why you did not disclose these
downgrades in your Form 10-Q filed on March 11, 2009.  Please revise your filing to disclose the implications of thes e credit downgrades to the following:
• Scheduled maturity dates of your debt;
• Availability of your credit lines
• Interest rates charged on your  debt and credit lines;
• Your debt covenant requirements; and
• Financial condition, results of  operations, and liquidity

*    *    *    *
       Please respond to these comments within 10 business days.  Please provide us with a response letter that keys your responses to  our comments and provides any requested
information.  Detailed letters greatly facilitate our review.  Please furnish your response on
EDGAR as a correspondence file.  Please unders tand that we may have additional comments
after reviewing your responses to our comments.

Mr. Ara K. Hovnanian
April 10, 2009 Page 3
You may contact Errol Sanderson, Financia l Analyst, at (202) 551-3746 or, in his
absence, Pamela Long, Assistant Director, at (202) 551-3760 if you have any questions regarding
legal matters.  Please contact Lisa Haynes, St aff Accountant, at ( 202) 551-3424 or, in her
absence, the undersigned at (202) 551-3689 if you have questions regarding comments on the
financial statements and related matters.

       S i n c e r e l y ,            John Hartz        Senior Assistant Chief Accountant