PHMPulteGroup

We appreciate the information that you have provided to us in response to our concerns about your segment reporting. We note the following about this information: - On page four of your letter dated May 19, 2011, you tell us that your CEO is your CODM.

Rest of the question

- In consultation with the CEO, each Area is provided with an invested capital target, which is used to determine the allocation of capital to the Divisions within that Area. - The Area capital allocations targets are reviewed by the CEO quarterly in order to monitor the Area’s progress with respect to its’ invested capital target. - All acquisitions and sales of land parcels exist under a formal process of approval by the corporate office. Please tell us whether this requires the CEO approval. - We note that the reporting package contains discrete financial information at the Company, Homebuilding, Area, Division and Community level. Please note our view. If information is provided to the CODM, it is presumed that he uses such information. Further, after review of such information, it appears to us that the level of detail is in fact quite normal and appropriate for a CEO and anything less may imply a weakness of internal control. In your letter, you note that ASC 280 stipulates that the segments are evident from the structure of the public entity. We agree. However it appears to us that your communities, or at a minimum, your Divisions, are your operating segments and any aggregation of them is required to be consistent with the objectives of the guidance. In your letter to us on June 19, 2006 you told us that your CODM consisted of three individuals, the Chief Executive Officer (CEO), the Chief Operating Officer (COO) and the Chief Financial Officer (CFO). In your letter dated May 19, 2011, you told us that the CODM is the Chief Executive Officer. Please tell us on what date this change was made. Explain to us how the reporting and decision functions changed. Please be very specific in your response, so that we may understand how the COO and CFO, were no longer able to be part of the CODM group. Provide us with contemporaneous information to support the date of change.

To clarify our previous responses, the Company’s formal process for the corporate office approving all acquisitions and sales of land parcels does not require the formal approval by the CEO for each such transaction.

Regarding the change in the CODM, the CEO assumed more direct responsibility for the Company’s homebuilding operations with the elimination of the COO position in August 2010 (see Form 8-K filed August 12, 2010). Under the revised structure, the

Area Presidents report directly to the CEO along with certain other positions that previously reported to the COO.

Rest of the answer

In conjunction with these changes, the CODM changed to the CEO because the CEO has the ultimate responsibility “to allocate resources to and assess the performance of” (ASC 280-10-50-5) the Company’s operations.

Regarding the determination of operating segments, ASC 280-10-50-1 states:

“b. Its operating results are regularly reviewed by the public entity’s chief operating decision maker to make decisions about resources to be allocated to the segment and assess its performance.” (emphasis added)

We respectfully submit that the CEO assesses performance and allocates resources for our Homebuilding operations at the Area level. A variety of information, including the information we submitted, is used to assess the performance of the Areas and determine each Area’s invested capital targets. The Area presidents are in turn responsible for assessing performance and allocating capital within their respective Areas. We would also like to highlight that the Division presidents do not meet the definition of a segment manager, which ASC 280-10-50-7 describes as one that is “directly accountable to and maintains regular contact with the chief operating decision maker to discuss operating activities, financial results, forecasts, or plans for the segment”. In our organization, these criteria accurately describe our Area presidents.

We continue to believe that our

Areas represent our operating segments. In the event that you were to conclude that our Divisions represent our operating segments, we believe that the most appropriate aggregation of our Divisions would be in accordance with our Area structure in order to align with our internal organizational structure. This allows investors to see our Homebuilding operations from management’s vantage point. Presenting our Homebuilding operations in an alternative format would be inconsistent with how our operating results are reviewed and evaluated internally. Accordingly, whether our Areas or our Divisions are deemed to be the operating segments for our Homebuilding operations, we believe that our presentation of reportable segments is consistent with the objectives of ASC 280.

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We have considered your responses to our comments and the supplemental CODM materials you have furnished. Please note our view that the receipt of materials by the CODM indicates that such information is used by the CODM to make informed decisions regarding resource allocations and to assess performance.

Rest of the question

Based on the CODM materials you have provided, it appears to us that, at the very least, your 23 “Divisions” represent your operating segments as defined in ASC 280-10-50-1. Please provide us an aggregation analysis of your Divisions that incorporates the criteria outlined in ASC 280- 10-50-11. It may be helpful to explain to us the relative weighting you ascribe each factor. Please note our view that geographic proximity would appear to be a significant factor in any aggregation analysis, considering the nature of your industry.

We note your view regarding the determination of our operating segments. In applying the criteria outlined in ASC 280-10-50-11, we considered the following (repeated from our response dated July 8, 2011 for ease of reference):

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Nature of the products and services - We are engaged in the acquisition and development of land and the construction of residential housing on such land within the United States. Our Divisions offer similar products, including single family detached and attached housing.

Rest of the answer

One of our key strategic initiatives is to continue standardizing and reducing the number of floor plans and home designs offered to our customers nationally.

Nature of the production processes - All Divisions employ similar processes for constructing homes and follow national construction standards. Construction work is generally performed by independent contractors under similar contracts. We also enter into many national purchasing contracts that standardize our materials and pricing across our Homebuilding operations.

Type or class of customer for products and services - We construct and sell homes to individual customers throughout the United States and service the majority of major customer groups, including first-time, move-up, and active adult customers. We develop communities and construct homes targeted towards these major customer groups using a standardized process to segment potential customers into well-defined buyer profiles.

Methods used to distribute products or provide services - We sell homes using company sales personnel and model homes generally located on-site at local communities. We also employ various national marketing and customer relations programs, including standardized processes for sales practices, communication with the customer throughout the construction process, and post-sale customer satisfaction surveys.

Regulatory environment - We operate in a regulatory environment that is substantially similar across our operations. For example, sales personnel are required to follow federal Real Estate Settlement Procedures Act and Fair Housing Act guidelines and many of our land development and construction activities are subject to the same federal rules and regulations. While each community is subject to the requirements of local municipal authorities, the approval processes for plan development, permitting, and house construction are similar across all geographies.

We have provided on a supplemental basis under separate cover the requested aggregation of our Homebuilding operations into reportable segments based on the view that each of our Divisions represents an operating segment. Based on the similarities across our Homebuilding operations and consistent with the SEC's expressed views, we believe our proposed aggregation, which considers geographic proximity as a significant factor, provides an appropriate presentation of our Homebuilding operations in accordance with ASC 280.

We intend to adopt this revised segment presentation in conjunction with our Form 10-K for the year ending December 31, 2011, including reclassification of applicable segment information for all prior periods presented.

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