-----BEGIN PRIVACY-ENHANCED MESSAGE----- Proc-Type: 2001,MIC-CLEAR Originator-Name: webmaster@www.sec.gov Originator-Key-Asymmetric: MFgwCgYEVQgBAQICAf8DSgAwRwJAW2sNKK9AVtBzYZmr6aGjlWyK3XmZv3dTINen TWSM7vrzLADbmYQaionwg5sDW3P6oaM5D3tdezXMm7z1T+B+twIDAQAB MIC-Info: RSA-MD5,RSA, GicnyE4KsXYfeItKzvtw/QNDRbMap6yAXi+GF8rx7Q0Gf2WkY06cAyWOgo44vWi3 afuL6v7SExjl2OKrFUN1/w== 0000000000-06-015471.txt : 20061130 0000000000-06-015471.hdr.sgml : 20061130 20060331155246 ACCESSION NUMBER: 0000000000-06-015471 CONFORMED SUBMISSION TYPE: UPLOAD PUBLIC DOCUMENT COUNT: 1 FILED AS OF DATE: 20060331 FILED FOR: COMPANY DATA: COMPANY CONFORMED NAME: BEAZER HOMES USA INC CENTRAL INDEX KEY: 0000915840 STANDARD INDUSTRIAL CLASSIFICATION: OPERATIVE BUILDERS [1531] IRS NUMBER: 582086934 STATE OF INCORPORATION: DE FISCAL YEAR END: 0930 FILING VALUES: FORM TYPE: UPLOAD BUSINESS ADDRESS: STREET 1: 5775 PEACHTREE DUNW00DY RD STREET 2: STE B 200 CITY: ATLANTA STATE: GA ZIP: 30342 BUSINESS PHONE: 4042503420 MAIL ADDRESS: STREET 1: 5775 PEACHTREE DUNWOODY RD STREET 2: STE C-200 CITY: ATLANTA STATE: GA ZIP: 30342 LETTER 1 filename1.txt Mail Stop 7010 March 14, 2006 Via U.S. mail and facsimile Ian J. McCarthy President and Chief Executive Officer Beazer Homes USA, Inc. 1000 Abernathy Road, Suite 1200 Atlanta, GA 30328 RE: Beazer Homes USA, Inc. Form 10-K for the Fiscal Year Ended September 30, 2005 Forms 10-Q for the Fiscal Quarter Ended December 31, 2005 File No. 1-12822 Dear Mr. McCarthy: We have reviewed your response letter dated March 13, 2006 and have the following additional comment. If you disagree, we will consider your explanation as to why our comment is inapplicable. In of our comment, we may ask you to provide us with supplemental information so we may better understand your disclosure. After reviewing this information, we may raise additional comments. Form 10-K for the Fiscal Year Ended September 30, 2005 Notes to Financial Statements (1) Summary of Significant Accounting Policies Presentation, page 39 We read your response to our comment 4 from our letter dated March 1, 2006. Your response does not currently support your conclusion that your operating segments have similar characteristics and thus can be aggregated, for you have not demonstrated this to us and have not addressed the apparent differences in their economic characteristics and trends. Your response states "the economic characteristics which drive the sale of [your] homebuilding products, and the homebuilding industry in general, are the same within each of [your] geographic locations. These characteristics include employment growth and levels of unemployment, the general health of the local economy..." Please tell us what consideration you gave to the following: * Your disclosure on page 22 of your Form 10-K for the fiscal year ended September 30, 2005 states that the factors which contributed to the $130.2 million goodwill impairment charge were certain underperforming markets in Indiana, Ohio, Kentucky and Charlotte, North Carolina. The forecasts and valuations of the respective divisions, along with weaker than anticipated local economies, particularly in the Midwest markets, and severe price competition, particularly at entry level price points; * The differences in the economies driving certain of your markets, which have affected your orders and revenues, some of which you have described in paragraphs six and seven of your response; and * The availability of land and your ability to purchase land in certain regions of the country, which will impact your future economic performance in these regions. Please tell us how you determined the above were similar economic characteristics, which result in similar long-term financial performance and trends. Please provide us with your key metrics used in your quantitative analysis for each of the last five fiscal years, the most recent interim periods, and each subsequent year and interim period for which you have budgeting information for. Please include in your analysis explanations for any apparent differences in economic characteristics for a given operating segment when compared to another operating segment for a period and why these differences would not be considered an indication of differences in economic characteristics. Please ensure you also include explanations for any difference in trends, including your basis for concluding that any trend was temporary. Refer to paragraphs 17-18 and 73-74 of SFAS 131; Question 8 of the FASB Staff Implementation Guide for SFAS 131; and Topic 5 from the minutes of the November 10, 1998 meeting between the Professional Standards Group and the SEC staff. * * * * As appropriate, please respond to this comment within 10 business days or tell us when you will provide us with a response. Please furnish a letter that keys your responses to our comment and provides any requested supplemental information. Detailed response letters greatly facilitate our review. Please file your response letter on EDGAR. Please understand that we may have additional comments after reviewing your response to our comment. If you have any questions regarding this comment, please direct them to Meagan Caldwell, Staff Accountant, at (202) 551-3754 or, in her absence, to the undersigned at (202) 551-3769. Sincerely, Rufus Decker Accounting Branch Chief ?? ?? ?? ?? Ian J. McCarthy Beazer Homes USA, Inc. March 14, 2006 Page 1 of 3 UNITED STATES SECURITIES AND EXCHANGE COMMISSION WASHINGTON, D.C. 20549-7010 DIVISION OF CORPORATION FINANCE -----END PRIVACY-ENHANCED MESSAGE-----