United States securities and exchange commission logo
October 26, 2021
Bill W. Wheat
Chief Financial Officer
D.R. Horton, Inc.
1341 Horton Circle
Arlington, Texas 76011
Re: D.R. Horton, Inc.
Form 10-K for the
Fiscal Year Ended September 30, 2020
Response dated
September 29, 2021
File No. 001-14122
Dear Mr. Wheat:
We have reviewed your September 29, 2021 response to our comment
letter 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. Unless we note otherwise, our references to prior comments are
to comments in our
September 15, 2021 letter.
Form 10-K for the Fiscal Year Ended September 30, 2020
General
1. Refer to prior comment
1. Please tell us in quantified terms what your capital
expenditures for
climate related projects were for the years ended September 30, 2020 and
September 30, 2021. In
your response, please describe the nature of the climate-related
projects you
considered, including any planned future expenditures, and explain how you
determined that the
amounts were not material.
2. Your response to prior
comment 2 states that you have not experienced material indirect
consequences of
climate-related regulation or business trends and that you do not believe
that they are
reasonably likely to have a material impact on the specific aspects of your
business that you
referenced. It appears that your response is conclusory in nature and
does not adequately
address the individual items in our prior comment. Please describe
Bill W. Wheat
D.R. Horton, Inc.
October 26, 2021
Page 2
the climate-related regulations or business trends and the indirect
consequences from them
that you considered in your analysis and explain how you concluded they
were not
material.
3. Refer to prior comment 3. You state that you disclosed in a risk factor
that weather
conditions and natural disasters could adversely affect your business;
however, your
response does not appear to discuss the significant physical effects of
climate change on
your operations and results. Accordingly, please discuss the physical
effects of climate
change on your operations and results or explain in greater detail how
you concluded that
such effects have been, and are expected to continue to be, immaterial to
your operations
and results. In order to help us assess your response, please provide a
quantification of
weather-related damages to your property or operations, a discussion of
how weather
related impacts have affected or may affect your customers and suppliers
and a discussion
of any weather-related impacts on the cost or availability of insurance.
4. In response to prior comment 4 you state that you currently have no
pending litigation
related to climate change and that you will "adjust your risk factor
disclosure as
necessary" to reflect the potential for litigation risks. Please tell us
how you considered
providing disclosure at this time addressing the possibility of
climate-related litigation and
its potential impact.
5. Your response to prior comment 5 states that the compliance costs related
to climate
change you have incurred are not material to your financial position or
results from
operations and that you do not reasonably expect such costs to be
material in the
foreseeable future. Please tell us about the compliance costs you have
incurred and
explain how you concluded the related amounts were not material.
You may contact Maryse Mills-Apenteng at 202-551-3457 or Pam Long at
202-551-
3765 with any questions.
Sincerely,
FirstName LastNameBill W. Wheat
Division of
Corporation Finance
Comapany NameD.R. Horton, Inc.
Office of Real
Estate & Construction
October 26, 2021 Page 2
cc: Thomas B. Montano
FirstName LastName