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
Division of Corporation Finance
United States Securities and Exchange Commission
100 F. Street, N.E.
Washington, D.C. 20549
Re: | 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:
1. | West – Arizona, California and Nevada markets | ||
2. | Mountain – Colorado and Utah markets | ||
3. | East – Virginia and Maryland markets | ||
4. | Other Homebuilding – Delaware Valley, Illinois, Florida and Texas markets |
Additionally, the Company will restate its historical segment disclosures by amending the following SEC filings:
1. | December 31, 2005 Form 10-K | ||
2. | March 31, 2006 Form 10-Q | ||
3. | June 30, 2006 Form 10-Q |
Ms. Melissa Rocha, CPA
U. S. Securities and Exchange Commission
September 8, 2006
Page 2
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
Chief Financial Officer