SecProbe.io

February 7, 2025
Brad O' Connor
Chief Financial Officer
Hovnanian Enterprises, Inc.
90 Matawan Road
Fifth Floor
Matawan, NJ 07747
Re:Hovnanian Enterprises, Inc.
Form 10-K for the year ended October 31, 2024
Form 8-K filed December 5, 2024
File No. 001-8551
Dear Brad O' Connor:
            We have reviewed your filing and have the following comment.
            Please respond to this letter within ten business days by providing the requested
information or advise us as soon as possible when you will respond. If you do not believe a
comment applies to your facts and circumstances, please tell us why in your response.
            After reviewing your response to this letter, we may have additional comments.
Form 8-K filed on December 5, 2024
Ex. 99.1 Earnings Press Release - Fiscal Fourth Quarter and Year Ended October 31, 2024,
page 5
We note your presentation of adjusted earnings before interest and income taxes
return on investment ("adjusted EBIT ROI") as a non-GAAP financial measure for
which you disclose the most directly comparable GAAP financial measure is net
income. In regards to your presentation of adjusted EBIT ROI, please further clarify
and expand your disclosure regarding the following:
Clearly state how such measure is calculated including the use of a trailing
twelve-month period in your presentation. In addition, please expand your
disclosure to highlight that each of the components, adjusted EBIT and
inventories less consolidated inventory not owned and capitalized interest plus
liabilities from inventory not owned, used to calculate adjusted EBIT ROI are
considered non-GAAP measures, describe the adjustments made to arrive at such
non-GAAP measures and identify their most directly comparable GAAP financial •1.

February 7, 2025
Page 2
measures;
•Reconcile your statement that the most directly comparable GAAP financial
measure to your calculation of adjusted EBIT ROI is net income given that such
measure appears to be a ratio. In that regard, we note your discussion of your
trailing twelve return on equity ("ROE") on page 3. To the extent you view ROE
as the most directly comparable GAAP financial ratio, please tell us how the
Company determined that such measure is considered the most directly
comparable ratio as calculated using the most directly comparable GAAP
financial measures; and
•Notwithstanding the prior point, please revise your disclosures to also provide the
ratio as calculated using the most directly comparable GAAP financial measures
on a trailing twelve-month period.
            We remind you that the company and its management are responsible for the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action or absence
of action by the staff.
            Please contact Ameen Hamady at 202-551-3891 or Isaac Esquivel at 202-551-3395 if
you have questions regarding comments on the financial statements and related matters.
Sincerely,
Division of Corporation Finance
Office of Real Estate & Construction