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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

Date
August 30, 2018
Author
Charles Merdian
Form
UPLOAD
Company
LGI Homes, Inc. (LGIH) (CIK 0001580670)

Letter

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

Show Raw Text
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