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VIA EDGAR AND FACSIMILE

	May 25, 2006

Mr. John M. Hartz
Securities and Exchange Commission
Division of Corporation Finance
100 F Street, N.E.
Washington, D.C. 20549
Mail Stop 7010
Dear Mr. Hartz:
We have prepared the following in response to your comment letter dated
April 20, 2006 with respect to the following:
Hovnanian Enterprises, Inc.
File Number: 1-8551
Form 10-K for the fiscal year ended October 31, 2005 and Form 10-Q for
the quarter ended January 31, 2006
The paragraphs that follow respond to the questions asked under each of
the respective headers in your letter.  For convenience of reference,
the text of the comments in your letter has been reproduced in italics
herein.
We trust that you will find these responses acceptable, however, if you
have further questions or comments, please contact me at 732-747-7800.
Sincerely,
/S/J. LARRY SORSBY
J. Larry Sorsby
Executive Vice President and Chief Financial Officer

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 what the revisions
will look like.  These revisions should be included in your future
filings, including your interim fillings where applicable.

Residential Development Activities, Page 7:
       2.  You disclosed that the number of new homes sales contracted
slightly in the West Region due to the timing of the opening 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 contracts 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 factors, you should expand these types
of discussions in future filings.
	We will include a discussion of factors impacting sales and the
timing of the opening of new communities in future filings.  Relevant
factors include:  the availability of homes for sale in the current year
compared to the prior year, the number of communities that are open for
sale throughout the year, how long each community is open during the
year, the number and type of homes in each community, the number of lots
that are either delivered to us or developed internally to be made
available for sale and the regulatory environment.

Management's Discussion and Analysis of Financial 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.
	We have not discussed cancellation rates in prior filings with the
Commission because our rates of cancellation have historically been
relatively steady (plus or minus 3% quarter to quarter).  In the first
and second quarters of 2006, we have seen an increase in cancellation
rates.  Our future filings will include a discussion of relevant
cancellation rates, including in relation to historical levels.

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.
	In response to the Staff's comment, we will present restricted
cash held in escrow separately on face of the balance sheet.  We note
that we currently show restricted cash held in escrow in Note 5 to the
financial statements.

Consolidated Statements of Cash Flows, Page F-7:
	5.  In future filings, do not include restricted cash in the cash
total in your statements of cash flows.  Please refer to Rule 5-02 of
Regulation S-X.
	In response to the Staff's comment, we will not include restricted
cash in the cash total in the statements of cash flows in future
filings.

	6.  Given the various acquisitions of homebuilders in recent
years, in future filings please disclose separately the amounts paid to
acquire homebuilding companies and the amounts paid to purchase
property, equipment and other fixed assets in net cash used in investing
activities.  Please refer to SFAS 95.
	SFAS 95, paragraph 17 lists the items that should be included in
cash outflows for investing activities.  It separately lists in items
17b and 17c, payments to acquire equity instruments of other enterprises
and payments to acquire property, plant and equipment and other
productive assets, respectively.  For each of the acquisitions in the
last three years, we acquired the assets and certain related liabilities
of the homebuilders and not the equity, therefore, we included these
purchases in the amounts paid for property, plant and equipment and
other productive assets.  We chose to include in the description of that
line item "and acquisition of homebuilders" to help explain why the
amounts fluctuated from year to year.

	We also note that none of these acquisitions have exceeded the
significance thresholds, individually or in the aggregate, for separate
financial statement disclosure required by Regulation S-X Article 3-05.
Although the thresholds of Article 3-05 do not apply directly to the
SFAS 95 discussion of disclosing the amounts paid to acquire
homebuilding companies, we believe that because the amounts were not
significant for Article 3-05 purposes they could properly be combined
with the amounts paid to purchase property, plant and equipment.

	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
flows associated with investments in unconsolidated subsidiaries and
cash flows associated with distributions of capital from unconsolidated
subsidiaries in your statements of cash flows.  Please refer to SFAS 95.
	Footnote 18 provides condensed balance sheets and income
statements for our joint ventures as if they were consolidated.  The
amounts referenced in your comment are the total assets of the joint
ventures in which we have investments as of October 31, 2005 and 2004
and not our investment in these joint ventures.  Our investments in
these joint ventures were $187.2 million and $40.8 million as of October
31, 2005 and 2004, respectively, as shown on our consolidated balance
sheets and stated in the paragraph following the balance sheet tables in
footnote 18.  In future filings, we will separately disclose the
investment in unconsolidated joint ventures and the returns of capital
from unconsolidated subsidiaries as required by SFAS 95, paragraphs 16
and 17.

Note 1.  Basis of Presentation and Segment Information, Page F-8:
	8.  We note significant regional information in both your Business
section and MD&A.  Please provide a comprehensive analysis explaining
how you have defined your reportable segments.  For example, we assume
that your operating segments are at a lower level for purposes of
managing your business and that you have aggregated certain operating
segments.  We may have further comment.
	As the Staff's comment assumes, our homebuilding operating
segments are at a lower level than the regional information provided in
the Business section and MD&A.  We provide this regional information to
enhance our Business and MD&A disclosure.

	SFAS 131 defines an operating segment as a component of an
enterprise:
a.	That engages in business activities from which it may earn
revenues and incur expenses
b.	Whose operating results are regularly reviewed by the enterprise's
chief operating decision maker to make decisions about resources
to be allocated to the segment and assess its performance, and
c.	For which discrete financial information is available.

	Based on this definition, each one of our communities is an
operating segment, because the chief operating decision maker determines
resource allocation and analyzes performance at the discrete community
level.  In addition, our financial services business is an operating
segment, because it is managed and operated separately from the
homebuilding communities, and we report it as such.  However, under
paragraphs 18 and 19 of SFAS 131, we aggregate our communities into one
operating segment ("homebuilding") for financial reporting purposes
because none of the communities meet any of the quantitative thresholds
in paragraph 18:
a.	10% or more of the combined revenue of all operating segments
b.	10% or more of the combined reported profit of all operating
segments
c.	10% or more of the combined assets of all the operating segments.

	Also, in accordance with paragraph 19, the combined segments
(individual communities) share a majority of the aggregation criteria in
paragraph 17.  Specifically, with respect to each of the aggregation
criteria:
a.	The nature of the products and services - In each of these
communities we design, construct and market single family or
multi-family homes.  While tailored to appeal to specific market
tastes for the respective community, we develop lots and build and
sell homes to United States' consumers.  We develop our plans on a
project by project basis, utilizing our expertise to develop a
plan that we believe will allow the project to deliver returns
consistent with our overall business strategy of maximizing the
total return on equity over the long term.  The criteria used to
assess project viability and determine project approval are the
same across all projects.
b.	The nature of the production process - The skills, methodologies
and production processes used in developing land and building
homes in each of the communities are very similar to identical
across all communities.
c.	The type or class of customer for their products and services - We
sell our product to homeowners in the United States.  While
communities may target different price ranges for these homes, we
believe that our customers are similar in that this will be one of
the most significant purchases in their lives, and therefore the
relative significance to each customer is the same.
d.	The methods used to distribute their products or provide their
services - In connection with sales, we establish sales centers
and models and undertake marketing initiatives to raise awareness
of the communities.  This is a process consistently applied, with
slight community specific modifications, across all communities.
e.	If applicable, the nature of the regulatory environment - Banking
relationships and lending facilities are consistent in nature and
type across all communities as most are generated centrally by
Corporate.  In addition, Corporate also obtains insurance on a
centralized basis.  Each of the communities is impacted by their
local municipalities and utilities, but these local requirements
are comparable across all communities.

	Based on the above, we believe that our operating segments
(individual communities) can be aggregated into a single "homebuilding"
operating segment for reporting purposes, in accordance with paragraphs
18 and 19 of SFAS 131.

	9.  In future filings, please disclose your accounting policy and
the factors that you consider in determining whether or not to
consolidate joint ventures where you are the manager of the joint
venture.
	In future filings we will add disclosure to Note 2 - Summary of
Significant Accounting Policies and to the critical accounting policies
discussed in the MD&A, to expand on the discussion currently included in
Note 18 regarding the factors that we consider in determining whether or
not to consolidate joint ventures where we are the manager of the joint
venture.  We anticipate that the additional disclosure will be as
follows:

"Our ownership interest in joint ventures varies but is generally
less than or equal to 50 percent.  In determining whether or not
we must consolidate joint ventures, where we are the managing
member of the joint venture, we consider the guidance in EITF 04-5
in assessing whether the other partners have specific rights to
overcome the presumption of control by us as the manger of the
joint venture.  In most cases, the presumption is overcome because
the joint venture agreements require that both partners agree on
establishing the operating and capital decisions of the
partnership, including budgets, in the ordinary course of
business."

	10.  In future filings, please provide enterprise-wide product-
line disclosures for each group of similar product as required by
paragraph 37 of the 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 enterprises if a range of products and services are offered.
	Paragraph 37 of SFAS 131 requires an enterprise to report the
revenues from external customers for each product and service or each
group of similar products and services unless it is impracticable to do
so.  We believe we currently do this by providing revenues from Sale of
Homes, Land Sales, and Financial Services all separately on the face of
the income statement.  Sale of Homes revenues include all revenues from
the homes delivered in our different communities.  Communities can have
different types of homes, single-family, town-homes, condominiums, etc.;
however we believe that these are similar products (a residence for the
customer) and should be grouped.  Land sales are disclosed separately
because those are a different customer type, generally another builder
or land developer.  Finally, financial services revenue relates to our
financial services products (mortgage origination and title services)
and is provided separately.  Therefore, we respectfully submit to the
Staff that we believe our current disclosure complies with the
requirements of paragraph 37 of SFAS 131.

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.
	We make the distinction between products with a construction cycle
less than 12 months or more than 12 months based on our interpretation
of SFAS 66.

	The Decision Tree in Appendix F of SFAS 66 references Paragraph 20
of SFAS 66 with respect to the question of whether we are constructing
condos, office buildings, etc.  Paragraph 20 states, "The deposit method
of accounting described in paragraphs 65-67 shall be used until a sale
has been consummated.  .... However, because of the length of the
construction period of office buildings, apartments, condominiums,
shopping centers, and similar structures, such sales and the related
income may be recognized during the process of construction, subject to
the criteria in Paragraphs 41 and 42."

	It is our interpretation that SFAS 66, Paragraph 20, allows
percentage of completion accounting for buildings with a long
construction time.  Based on SOP 81-1, long term contracts that require
percentage of completion are generally projects that are longer than one
year.  Therefore, we use a 12 month construction time threshold as the
first consideration for percentage of completion accounting.  If the
construction time is less than 12 months we recognize revenue when the
title is conveyed to the buyer, adequate cash payment has been received
and there is no continued involvement.  If the construction time is
longer than 12 month