May 10, 2019

John Sznewajs
Chief Financial Officer
MASCO CORP /DE/
17450 College Parkway
Livonia, MI 48152

       Re: MASCO CORP /DE/
           Form 10-K for Fiscal Year Ended December 31, 2018
           Filed February 7, 2019
           File No. 001-05794
           Response Letter Filed May 8, 2019

Dear Mr. Sznewajs:

       We have reviewed your response and have the following comments. In some
of our
comments, we may ask you to provide us with information so we may better
understand your
disclosure.

       Please respond to these comments 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
comments apply to your facts and circumstances, please tell us why in your
response.

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

Form 10-K for Fiscal Year Ended December 31, 2018

Management's Discussion and Analysis of Financial Condition and Results of
Operations
Liquidity and Capital Resources
Cash Flows, page 22

1.    We have reviewed your response to our prior comment. Please address the
following:

          Tell us the dollar amount of accounts payable that were settled via
your supply chain
          finance program for each year from 2012 to 2018.
          Tell us the balance of your accounts payable that represents amounts
due to
          participating financial institutions under your supply chain finance
programs as of
          each year from 2012 to 2018.
          Provide us an analysis to support your conclusion that amounts
settled under your
          supply chain finance program are accounts payable rather than bank
financing. Your
 John Sznewajs
MASCO CORP /DE/
May 10, 2019
Page 2
             analysis should also address the classification of your payments
made to the
             participating financial institutions as well as related disclosure
of non-cash financing
             activities required by ASC 230-10-50-3.
             You state in your response that the payment terms to the
participating financial
             institution are the same as if you paid the supplier directly.
Please tell us the terms of
             your supply chain finance arrangements with the participating
financial institutions as
             well as the payment terms with your vendors.
             You also state in your response that the program improved your
accounts payable
             days. Please explain how the supply chain finance program
increased your accounts
             payable days outstanding.
             Tell us the extent to which the continued improvement to your
accounts payable days,
             and related liquidity, are expected to continue as well as the
factors, such as changes in
             interest rates, that may limit the availability of your supply
chain finance programs.
             To the extent material, expand your management's discussion and
analysis to address
             the impact the supply chain finance program has had on your
liquidity and whether or
             not that impact is expected to continue.
             Please ensure you have filed as exhibits, all agreements relating
to your supply chain
             finance program.
       In closing, 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.

       You may contact Kevin Stertzel, Senior Staff Accountant at (202)
551-3723 or W. John
Cash, Branch Chief at (202) 551-3768 with any questions.



                                                                Sincerely,
FirstName LastNameJohn Sznewajs
                                                                Division of
Corporation Finance
Comapany NameMASCO CORP /DE/
                                                                Office of
Manufacturing and
May 10, 2019 Page 2                                             Construction
FirstName LastName