SecProbe.io

Mail Stop 4631

May 31, 2017

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, 2016
Filed February 28, 2017
  Definitive Proxy Statement on Schedule 14A
  Filed March 7, 2017
  File No. 1-35166

Dear Mr. Wyatt :

We have reviewed your filing  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.

Definitive Proxy Statement on Schedule 14A filed March 7, 2017

Compensation Discussion and Analysis, page 18

1. In future filings, please clearly disclose the minimum, target, and maximum for
performance goals and payout levels for your incentive plan compensatio n.  The grants of
plan-based awards table should include threshold, target, and maximum estimated future
payouts under equity and non -equity incentive plans.  Please provide us proposed revised
disclosure.

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 a bsence of
action by the staff.

Mr. E. Lee Wyatt, Jr.
Fortune Brands Home & Security, Inc.
May 31, 2017
Page 2

You may contact Edward M. Kelly, Senior Counsel, at (202) 551 -3728 or Asia Timmons -
Pierce, Staff Attorne y, at (202) 551 -3754 with any questions.

 Sincerely,

 /s/ John  Cash

 John Cash
 Accounting Branch Chief
Office of Manufacturing and
Construction