SecProbe.io

May 10 , 2016

Mail Stop 4631

Via E -mail
Mr. E. Lee Wyatt, Jr.
Senior Vice President and Chief Financial Officer
Fortune Brands Home & Security , Inc.
520 Lake Cook Road
Deerfield, IL  60015 -5611

RE: Fortune Brands Home & Security, Inc.
Form 10 -K for the Year Ended December 31, 2015
Filed February 25, 2016
  File No. 1 -35166

Dear Mr. Wyatt :

We have limited our review  of your filing  to the financial statements and related
disclosures 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 believe 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.

Item 8. Financial Statements and Supplementary Data

Note 4. Acquisitions, page 56

1. We note that you recorded customer relationships of $210 million as a result of the Norcraft
acquisition, and the useful life of the customer relat ionships is estimated to be twenty years.
We further note your disclosure on page 60 that you have customer and contractual
relationships of $333.8 million as of December 31, 2015, which are subject to amortization
over an estimated useful life ranging fr om three to thirty years.  Please clarify your disclosure
to state whether customer relationships are amortized on the straight -line method or an
accelerated method that aligns with customer attrition.  If you amortize customer
relationships using the stra ight-line method rather than an accelerated method, please tell us
why you believe this method reflects the pattern in which the economic benefits are
consumed or explain why you cannot reliably determine the pattern in accordance with ASC
350-30-35-6.  Note that customer relationships may dissipate at a more rapid rate in the

Mr. E. Lee Wyatt, Jr.
Fortune Brands Home & Security , Inc.
May 10 , 2016
Page 2

 earlier periods following a company´s succession to these relationships, with the rate of
attrition declining over time until relatively few customers remain who persist for an
extend ed period.  Under this pattern, a significant amount of cash flows derived from the
acquired customer base may be recognized in earlier periods and then fall to a materially
reduced level in later years.  In this regard, an accelerated method of amortizati on, rather than
the straight -line method, may be the most appropriate and systematic allocation of the
intangibles´ cost to the periods benefited.

We urge all persons who are responsible for the accuracy and adequacy of the disclosure
in the filing to b e certain that the filing includes the information the Securities Exchange Act of
1934 and all applicable Exchange Act rules require.   Since the company and its management are
in possession of all facts relating to a company’s disclosure, they are responsi ble for the accuracy
and adequacy of the disclosures they have made.

 In responding to our comments, please provide  a written statement from the company
acknowledging that:

 the company is responsible for the adequacy and accuracy of the disclosure in the filing;

 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.

You may contact Jeffrey Gordon, Staff Accoun tant, at (202) 551 -3866 or me at (202)
551-3854 with any questions.

 Sincerely,

 /s/ M elissa N. Rocha

 Melissa N.  Rocha
 Senior Assistant Chief Accountant
Office of Manufacturing and
Construction