September 8, 2006
Via EDGAR
Ms. Melissa N. Rocha, CPA
Division of Corporation Finance
United States Securities and Exchange Commission
100 F. Street, N.E.
Washington, D.C. 20549
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Re: |
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M.D.C. Holdings, Inc.
Form 10-K for Fiscal Year Ended December 31, 2005
Form 10-Q for the Fiscal Quarter Ended March 31, 2006
File No. 001-08951 |
Dear Ms. Rocha:
On behalf of M.D.C. Holdings, Inc. (the “Company” or “MDC”), we hereby provide the following
response to the comment contained in the letter dated August 3, 2006.
Form 10-K for Fiscal Year Ended December 31, 2005
Response: As a follow-up to the Commission’s comments concerning segment reporting, the
Company has concluded that it will commence disclosing the following reportable segments
for its homebuilding operations:
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1. |
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West – Arizona, California and Nevada markets |
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2. |
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Mountain – Colorado and Utah markets |
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3. |
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East – Virginia and Maryland markets |
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4. |
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Other Homebuilding – Delaware Valley, Illinois, Florida and Texas
markets |
Additionally, the Company will restate its historical segment disclosures by amending the
following SEC filings:
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1. |
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December 31, 2005 Form 10-K |
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2. |
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March 31, 2006 Form 10-Q |
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3. |
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June 30, 2006 Form 10-Q
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Ms. Melissa Rocha, CPA
U. S. Securities and Exchange Commission
September 8, 2006
Page 2
Please contact the undersigned with any questions at (303) 804-7706 or Joseph H. Fretz, Secretary
and Corporate Counsel of the Company at (303) 804-7730.
Sincerely,
M.D.C. Holdings, Inc.
/s/ Paris G. Reece III
Executive Vice President and
Chief Financial Officer