SEC Comment Letter for LGI Homes, Inc. (LGIH) (CIK 0001580670) (LGIH) — Aug 30, 2018
LGI Homes, Inc. (LGIH) (CIK 0001580670)
Date: Aug. 30, 2018 · CIK: 0001580670 · Accession: 0000000000-18-027036
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File numbers found in text: 001-36126
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August 30, 2018
Charles Merdian
Chief Financial Officer
LGI Homes, Inc.
1450 Lake Robbins Drive
Suite 430
The Woodlands, Texas 77380
Re:LGI Homes, Inc.
Form 10-K for Fiscal Year Ended December 31, 2017
Filed February 27, 2018
Response filed August 28, 2018
File No. 001-36126
Dear Mr. Merdian:
We have reviewed your August 28, 2018 response to our comment letter 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 business days by providing the requested
information or advise 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. Unless we note otherwise, our references to prior comments are to comments in our
August 14, 2018 letter.
Form 10-K for Fiscal Year Ended December 31, 2017
Item 7. Management’s Discussion and Analysis of Financial Condition and Results of
Operations
Results of Operations, page 32
1.While we understand that your business model focus may be different from your
competitors, it remains unclear why the homebuilding backlog data that you provide at the
consolidated level would not also be useful information for investors at the reportable
segment level. To the extent that the information is readily available, please provide the
FirstName LastNameCharles Merdian
Comapany NameLGI Homes, Inc.
August 30, 2018 Page 2
FirstName LastName
Charles Merdian
LGI Homes, Inc.
August 30, 2018
Page 2
homebuilding backlog data at the reportable segment level in addition to the consolidated
level.
You may contact Tracey Houser, Staff Accountant, at (202) 551-3736, or Jeanne
Baker, Assistant Chief Accountant, at (202) 551-3691, if you have questions regarding
comments on the financial statements and related matters.
Sincerely,
Division of Corporation Finance
Office of Manufacturing and
Construction