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Response Letter to SEC

 January 7, 2013

 VIA EDGAR

 Mr. Rufus Decker

 Accounting Branch Chief

 Division of Corporation Finance

United States Securities and Exchange Commission

Washington, DC 20549-7010

Re:
Fortune Brands Home & Security, Inc.

 Form 10-K for the Year Ended December 31, 2011

 Filed February 22, 2012

 Form 10-Q for the Period Ended September 30, 2012

Filed November 5, 2012

 Form 8-K

 Filed October 23, 2012

File No.1-35166

 Dear
Mr. Decker:

 Set forth below are the responses of Fortune Brands Home & Security, Inc. (the “Company”) to the comments
raised in the letter dated December 14, 2012 (the “Comment Letter”) from the staff (the “Staff”) of the Securities and Exchange Commission with respect to the above referenced filings. For the convenience of the Staff, the
Staff’s comments contained in the Comment Letter have been reproduced below and the Company’s responses thereto have been set forth immediately after each comment. We will reflect in our future filings the changes outlined herein, and we
acknowledge the following:

-

 The Company is responsible for the adequacy and accuracy of the disclosures in our filings;

-

 Staff comments or changes to disclosure in response to Staff comments do not foreclose the Commission from taking any actions 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.

 FORM 10-K FOR THE YEAR ENDED DECEMBER 31, 2011

General

1.
Where a comment below requests additional disclosures or other revisions to be made, please show us in your supplemental response what the revisions will look like.
These revisions should be included in your future filings, including your interim filings, if applicable.

Response:

Where our responses include additional or revised disclosures, we have shown or described what the revision will look like and we will
incorporate such disclosure in future filings, including our interim filings.

 Management’s Discussion and Analysis

Liquidity and Capitalization, page 36

Cash Flows, page 37

2.
In regards to your presentation of free cash flow, please ensure that you discuss all the material limitations of your measurement. For example, there are some
non-discretionary expenditures such as mandatory debt service commitments that have not been included in your determination of free cash flow. Refer to Compliance and Disclosure Interpretation 102.07 which is available on our website at
http://www.sec.gov/divisions/corpfin/guidance/nongaapinterp.htm.

 Response:

We respectfully submit that we discontinued the presentation of free cash flow in our Form 10-K and 10-Q filings effective with our Form
10-Q for the period ended March 31, 2012 which was filed on May 4, 2012. If we begin disclosing free cash flow in future Form 10-K or 10-Q filings, we will include disclosure regarding material limitations to the measurement. For example,
we would include disclosure similar to the following: “Free cash flow does not reflect adjustments for certain non-discretionary cash flows such as mandatory debt repayments.” We would also include the above disclosure in future Form
8-K’s that furnish financial information that includes free cash flow.

 2

 Contractual Obligations and Other Commercial Commitments, page 39

3.
Please revise your table of contractual cash obligations to include estimated interest payments on your debt. Because the table is aimed at increasing transparency of
cash flows, we believe these payments should be included in the table. Please also disclose any assumptions you made to derive these amounts in a footnote to the table.

Response:

Beginning with our Form 10-K for the year ended December 31, 2012 (“our 2012 Form 10-K”), we will revise the contractual
obligations table to include estimated interest payments on our debt.

 Below is an example of the revised disclosure and table
of contractual cash obligations that will include estimated interest payments on our debt. Changes in our disclosure are noted in italics.

 Contractual Obligations and Other Commercial Commitments

The following table describes our obligations and commitments to make future payments under contracts, such as debt and
lease agreements, and under contingent commitments, such as debt guarantees, as of December 31, 2011.

(In millions)

Payments Due by Period as of December 31, 2011

 Contractual Obligations

Total

Less than
1 year

1-3 years

4-5 years

After
5
years

 External short-term borrowings

$
3.8

$
3.8

$
—

$
—

$
—

 Total debt

406.8

17.5

63.2

319.3

6.8

 Interest payments on debt(a)

29.8

7.2

13.0

9.6

—

 Operating leases

84.1

27.8

34.3

14.9

7.1

 Purchase obligations(b)

243.7

237.0

3.7

2.0

1.0

 Defined benefit plan contributions(c)

26.6

26.6

—

—

—

 Total

$
794.8

$
319.9

$
114.2

$
345.8

$
14.9

(a)
 Interest payments on debt were calculated using the borrowing rate in effect on December 31,
2011.

(b)
 Purchase obligations include contracts for raw material and finished goods purchases; selling and administrative services; and capital expenditures. As
of December 31, 2011, there were no material commitments for capital expenditures.

(c)
 Minimum required contributions cannot be determined beyond 2012.

 3

 Critical Accounting Policies and Estimates

 Long-Lived Assets, page 42 and Goodwill and Indefinite-Lived Intangible Assets, page 42

4.
In the fourth quarter of 2011, you recorded asset impairment charges of $90.0 million related to indefinite-lived tradenames in the Advanced Material Windows &
Door Systems segment. These charges were primarily the result of reduced revenue growth and profit margin expectations associated with your Simonton tradename over the next two to three years. Please address what impairment considerations were given
to the remaining long-lived assets of Simonton pursuant to ASC 360-10.

 Response:

At December 31, 2011, we considered the reduced revenue growth and profit margin expectations related to Simonton to be trigger
events under ASC 360-10-35-21, and therefore tested the long-lived assets of Simonton for impairment pursuant to the requirements of ASC 360. The required undiscounted cash flow test indicated that the future cash flows of the assets were
substantially greater than their carrying values. As such, no impairments were identified or recorded related to Simonton long-lived assets.

5.
In the interest of providing readers with a better insight into management’s judgments in accounting for goodwill, please disclose the following:

•

 How you weight each of the methods used to value goodwill, including the basis for that weighting;

•

 How the methodologies used for valuing goodwill in the current year have changed since the prior year; and

•

 You disclose the estimated excess fair value of the Advanced Materials Windows & Doors Systems reporting units is less than 10%. Please
provide the following disclosures for each of these reporting units:

¡

 Identify the reporting unit;

¡

 The percentage by which fair value exceeds the carrying value of the most-recent step-one test;

¡

 The amount of goodwill and indefinite-lived tradenames;

¡

 A description of the assumptions that drive the estimated fair value;

¡

 A discussion of the uncertainty associated with the key assumptions. For example, to the extent that you have included assumptions in your discounted
cash flow model that materially deviates from your historical results, please include a discussion of these assumptions; and

¡

 A discussion of any potential events and/or circumstances that could have a negative effect to the estimated fair value.

Please refer to Item 303 of Regulation S-K and Sections 216 and 501.14 of the SEC’s Codification of Financial Reporting Policies
for guidance.

 Response:

 Beginning with our 2012 Form 10-K and as required in future filings, we will revise our disclosure with respect to Goodwill and Indefinite-lived Intangible Assets in our Critical Accounting Policies and
Estimates in a manner similar to the following. The new disclosure is shown below in italics:

 As of December 31,
2011, we evaluated the recoverability of goodwill using a weighting of the income (80%) and market (20%) approaches. For the income approach, we use a discounted cash flow model, estimating the future cash flows of the

 4

reporting units to which the goodwill relates and then discounting the future cash flows at a market-participant-derived weighted-average cost of capital. In determining the estimated future cash
flows, we consider current and projected future levels of income based on management’s plans for that business; business trends, prospects and market and economic conditions; and market-participant considerations. Furthermore, our cash flow
projections used to assess impairment of our goodwill and other intangible assets are significantly influenced by our projection for the recovery of the U.S. home products market in the next 3 to 5 years and our annual operating plans finalized in
the fourth quarter of each year. For the market approach, we apply market multiples for peer groups to the current operating results of the reporting units to estimate each reporting unit’s fair value. Prior to 2011, we relied solely
on the income approach to estimate fair value. The market approach was added to incorporate consideration of the disparity in values between the income approach and market approach caused by the cyclical nature of many of the Company’s
businesses. Predominant weight was put on the Company’s income approach (and future estimates of discounted cash flow) because we believe the recent historical operating results used in the market approach are not as relevant for valuation
purposes as they reflect depressed cash flows due to the recent U.S. recession and the significant decline in both new home construction and repair and remodel market activity relative to historic levels. The Company’s reporting units are
operating segments or one level below the operating segment. When the estimated fair value of a reporting unit is less than its carrying value, we measure and recognize the amount of the goodwill impairment loss, if any. Impairment losses, limited
to the carrying value of goodwill, represent the excess of the carrying value of a reporting unit’s goodwill over the implied fair value of that goodwill. The implied fair value of a reporting unit is estimated based on a hypothetical
allocation of each reporting unit’s fair value to all of its underlying assets and liabilities in accordance with the requirements of ASC 350. Both of the reporting units within Advanced Material Windows & Door Systems have tradenames
and goodwill. As of December 31, 2011, for the two reporting units within Advanced Material Windows & Door Systems, Therma-Tru’s fair value exceeded its carrying value by 4% and Simonton’s fair value exceeded its carrying
value by 6%. In addition, any future reduction in the estimated fair value of the indefinite-lived tradenames within these reporting units would result in an impairment charge. As of December 31, 2011, the amounts of goodwill and
indefinite-lived tradenames for the reporting units within the Advanced Material Windows & Door Systems segment were as follows:

 (In millions)

 Reporting unit

Goodwill

Indefinite-lived
Tradenames

 Therma-Tru entry doors

$
143.0

$
166.0

 Simonton windows

87.2

61.0

 5

 The significant assumptions that were used to determine the estimated fair value for
goodwill impairment testing included the following: third-party market forecasts of U.S. new home starts and home repair and remodel spending; management’s sales, profit and cash flow forecasts; peer company EBITDA earnings multiples; the
market-participant-based weighted-average cost of capital; and the perpetuity growth rate. The significant assumptions that were used to determine the estimated fair value for indefinite-lived tradename testing are third-party market forecasts of
U.S. new home starts and home repair and remodel spending; management’s sales and profit margin forecasts; the market-participant weighted-average cost of capital; and the perpetuity growth rate.

Our estimates of reporting unit fair values are based on certain assumptions that may differ from our historical and future actual
operating performance. Specifically, assumptions related to growth in the new construction and repair and remodel segments of the U.S. home products markets drive our forecasted sales growth. The market forecasts are developed using independent
third-party forecasts from multiple sources. In addition, estimated future profit margins and cash flow consider our historical performance at similar levels of sales volume and management’s future operating plans as reflected in annual and
long-term plans that are reviewed and approved by management.

 The events and/or circumstances that could have a
potential negative effect on the estimated fair value of our reporting units and indefinite-lived tradenames include: actual new construction and repair and remodel growth rates that lag our assumptions, actions of key customers, volatility of
discount rates, continued economic uncertainty, higher levels of unemployment, weak consumer confidence, and lower levels of discretionary consumer spending.

6.
For any long-lived assets or asset groups, including other intangible assets aside from goodwill, for which you have determined that undiscounted cash flows are not
substantially in excess of the carrying value and to the extent that the asset amounts, in the aggregate or individually, could materially impact your operating results or total shareholder’s equity, please disclose the following:

•

 The carrying values of the assets;

•

 The percentage by which undiscounted cash flows exceeds the carrying value;

•

 The carrying values of the assets;

•

 A description of the assumptions that drive the estimated fair value;

•

 A discussion of the uncertainty associated with the key assumptions. For example, to the extent that you have included assumptions in your discounted
cash flow model that materially deviates from your historical results, please include a discussion of these assumptions; and

•

 A discussion of any potential events and/or circumstances that could have a negative effect to the estimated fair value.

Please refer to Item 303 of Regulation S-K and Sections 216 and 501.14 of the SEC’s Codification of Financial Reporting Policies
for guidance.

 6

 Response:

 As of December 31, 2011, we did not identify any asset groups where undiscounted cash flows were not substantially in excess of carrying value. In accordance with ASC 360-10-35-21, we give
consideration to whether or not events or changes in circumstances indicate that an asset group’s carrying amount may not be recoverable. Because of the indefinite-lived intangible asset impairments referred to in Question 4, we tested the
asset groups within the Advanced Material Windows & Door Systems segment as of December 31, 2011 and concluded that the future undiscounted cash flows were substantially higher than the carrying value of the asset groups. We will
provide the disclosures listed above in future periods if we determine that undiscounted cash flows for any long-lived assets or asset groups are not substantially in excess of the carrying value.

Defined Benefit Plans, page 43

7.
In 2011, you recognized actuarial losses of $80 million related to defined benefit plans compared to a (loss) before income taxes of $43.6 million. On page 28, you
disclose that this was primarily due to a decrease in the discount rate as well as a lower than expected rate of return on pension plan assets. Given the significant impact that these actuarial losses had on your results of operations, please expand
your disclosures t