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SEC Comment Letter for HOVNANIAN ENTERPRISES INC (HOV, HOVNP, HOVVB) (CIK 0000357294) (HOV) — May 9, 2017

HOVNANIAN ENTERPRISES INC (HOV, HOVNP, HOVVB) (CIK 0000357294)
Date: May 9, 2017 · CIK: 0000357294 · Accession: 0000000000-17-016261

AI Filing Summary & Sentiment

Date
May 9, 2017
Author
/s/ John Cash
Form
UPLOAD
Company
HOVNANIAN ENTERPRISES INC (HOV, HOVNP, HOVVB) (CIK 0000357294)

Letter

Mail Stop 4631 May 9, 2017 Via E -mail Mr. J. Larry Sorsby, Chief Financial Officer Hovnanian Enterprises, Inc. 110 West Front Street, P.O. Box 500 Red Bank, NJ 07701

Re: Hovnanian Enterprises, Inc. Form 10-K for the year ended October 31, 2016 Filed December 20, 2016 File No. 1 -8551

Dear Mr. Sorsby :

We have reviewed your April 21, 2017 response to our comment letter and have the following comment . In our comment , we may ask you to provide us with information so we may better understand your disclosure.

Please respond to this comment within ten busine ss days by providing the requested information or advis e us as soon as possible when you will respond. If you do not beli eve our comment applies to your facts and circumstances, please tell us why in your response.

After reviewing your response to this comment, we may have additional comments. Unless we note otherwise, our references to prior comments are to comments in our March 27, 2017 letter .

Critical Accounting Policies, page 27

Deferred Income Taxes, page 30

As previously requested, please ensure you expand your disclosures to include sufficiently detailed information similar to the information you have pr ovided in your response to prior comment one so that readers understand the your significant assumptions as well as the analysis you performed in determining what portion of your deferred tax assets will more likely than not be realized.

Mr. J. Larry Sorsby Hovnanian Enterprises, Inc. May 9, 2017 Page 2

Please contact Mindy Hooker at (202) 551 -3732, Jeanne Baker at (202) 551 -3691 or me at (202) 551 -3768 with any questions.

Sincerely,
/s/ John Cash

Show Raw Text
Mail Stop 4631
May 9, 2017

Via E -mail
Mr. J. Larry Sorsby, Chief Financial Officer
Hovnanian Enterprises, Inc.
110 West Front Street, P.O. Box 500
Red Bank, NJ  07701

Re: Hovnanian Enterprises, Inc.
 Form 10-K for the year ended October 31, 2016
Filed December 20, 2016
File No. 1 -8551

Dear Mr. Sorsby :

We have reviewed  your April 21, 2017  response to our comment  letter  and have the
following comment .  In our comment , we may  ask you to provide us with information so we may
better understand your disclosure.

Please respond to this comment  within ten busine ss days by providing the requested
information or advis e us as soon as possible when you will respond.  If you  do not beli eve our
comment  applies to your facts and circumstances, please  tell us why in your response.

After reviewing your response to this comment, we may have additional comments.
Unless we note otherwise, our references to prior comments are to comments in our March 27,
2017  letter .

Critical Accounting Policies, page 27

Deferred Income Taxes, page 30

As previously requested, please ensure you expand your disclosures to include sufficiently
detailed information similar to the information you have pr ovided in your response to prior
comment one so that readers understand the your significant assumptions as well as the analysis
you performed in determining what portion of your deferred tax assets will more likely than not
be realized.

Mr. J. Larry Sorsby
Hovnanian Enterprises, Inc.
May 9, 2017
Page 2

 Please contact  Mindy Hooker at (202) 551 -3732, Jeanne Baker at (202) 551 -3691 or me
at (202) 551 -3768 with any questions.

        Sincerely,

/s/ John Cash

        John Cash
Branch Chief
Office of Manufacturing and
Construction