AV Homes, Inc.
8601 N. Scottsdale Rd., Suite 225
Scottsdale, Arizona 85253
June 29, 2017
VIA EDGAR
United States Securities and Exchange Commission
Division of Corporation Finance
100 F Street, N.E.
Washington, D.C. 20549
| Attention: | Jay Ingram, Legal Branch Chief | |
| Christopher Ronne, Staff Attorney |
| Re: | AV Homes, Inc. |
Registration Statement on Form S-4 (File No. 333-218953)
Ladies and Gentlemen:
Pursuant to Rule 461 under the Securities Act of 1933, as amended, AV Homes, Inc. (the “Company”) hereby respectfully requests that the effective date of the above referenced Registration Statement on Form S-4 be accelerated and that such Registration Statement be permitted to become effective at 4:00 p.m. Eastern Time on Monday, July 3, 2017, or as soon thereafter as possible.
Please contact Michael Coddington of Faegre Baker Daniels LLP, counsel to the Company, at (612) 766-7328, as soon as the Registration Statement has been declared effective, or if you have any other questions or concerns regarding this matter.
| Very truly yours, | ||
| AV HOMES, INC. | ||
| By: | /s/ S. Gary Shullaw | |
| Name: | S. Gary Shullaw | |
| Title: | Executive Vice President and General Counsel | |
cc: Michael Coddington, Faegre Baker Daniels LLP
