PHMPulteGroup

Please refer to comment seven in our letter dated April 29, 2011 and your response dated May 19, 2011. We note that you continue to disclose that the committee uses a guideline range of the 50th to 75th percentile of market data to establish target compensation levels; however you do not disclose where each element of actual compensation fell relative to the guideline range.

Rest of the question

Please revise your future filings to comply with our prior comment seven in full.

In future filings of our Proxy Statement, we will disclose where each element of actual compensation fell relative to any disclosed guideline range of target compensation levels for the relevant compensation element.

We acknowledge that:

•

PulteGroup, Inc. is responsible for the adequacy and accuracy of the disclosure in the filing;

staff comments or changes to disclosure in response to staff comments do not foreclose the Commission from taking any action with respect to the filing; and

PulteGroup, Inc.

Rest of the answer

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.

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