February 7, 2025

Brad O' Connor
Chief Financial Officer
Hovnanian Enterprises, Inc.
90 Matawan Road
Fifth Floor
Matawan, NJ 07747

       Re: Hovnanian Enterprises, Inc.
           Form 10-K for the year ended October 31, 2024
           Form 8-K filed December 5, 2024
           File No. 001-8551
Dear Brad O' Connor:

       We have reviewed your filing and have the following comment.

       Please respond to this letter 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 a
comment applies to your facts and circumstances, please tell us why in your
response.

       After reviewing your response to this letter, we may have additional
comments.

Form 8-K filed on December 5, 2024
Ex. 99.1 Earnings Press Release - Fiscal Fourth Quarter and Year Ended October
31, 2024,
page 5

1.     We note your presentation of adjusted earnings before interest and
income taxes
       return on investment ("adjusted EBIT ROI") as a non-GAAP financial
measure for
       which you disclose the most directly comparable GAAP financial measure
is net
       income. In regards to your presentation of adjusted EBIT ROI, please
further clarify
       and expand your disclosure regarding the following:
           Clearly state how such measure is calculated including the use of a
trailing
           twelve-month period in your presentation. In addition, please expand
your
           disclosure to highlight that each of the components, adjusted EBIT
and
           inventories less consolidated inventory not owned and capitalized
interest plus
           liabilities from inventory not owned, used to calculate adjusted
EBIT ROI are
           considered non-GAAP measures, describe the adjustments made to
arrive at such
           non-GAAP measures and identify their most directly comparable GAAP
financial
 February 7, 2025
Page 2

           measures;
             Reconcile your statement that the most directly comparable GAAP
financial
           measure to your calculation of adjusted EBIT ROI is net income given
that such
           measure appears to be a ratio. In that regard, we note your
discussion of your
           trailing twelve return on equity ("ROE") on page 3. To the extent
you view ROE
           as the most directly comparable GAAP financial ratio, please tell us
how the
           Company determined that such measure is considered the most directly
           comparable ratio as calculated using the most directly comparable
GAAP
           financial measures; and
             Notwithstanding the prior point, please revise your disclosures to
also provide the
           ratio as calculated using the most directly comparable GAAP
financial measures
           on a trailing twelve-month period.

        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 absence
of action by the staff.

       Please contact Ameen Hamady at 202-551-3891 or Isaac Esquivel at
202-551-3395 if
you have questions regarding comments on the financial statements and related
matters.



                                                            Sincerely,

                                                            Division of
Corporation Finance
                                                            Office of Real
Estate & Construction