May 16, 2019
Diane Bessette
Chief Financial Officer
LENNAR CORP
700 Northwest 107th Ave
Miami, Florida 33172
Re: LENNAR CORP
Form 10-K for the Fiscal Year Ended November 30, 2018
Filed January 28, 2019
Form 10-Q for the period ended February 28, 2019
Filed April 8, 2019
File No. 001-11749
Dear Ms. Bessette:
We have limited our review of your filing to the financial statements
and related
disclosures 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.
Response Dated May 13, 2019
Form 10-Q for the period ended February 28, 2019
Basis of Presentation
Recently Adopted Accounting Pronouncements, page 7
1. We note from your response to comment 1 of our letter dated May 1, 2019,
that there were
no significant changes to your revenue recognition accounting policies
from those noted
in your recent annual report on Form 10-K. We further note from the
revenue recognition
policies in your Form 10-K that you recognize revenue from (1) home sales
when the
sales are closed and title passes to the new homeowner, the new
homeowner's initial and
continuing investment is adequate to demonstrate a commitment to pay for
the home, the
new homeowner's receivable is not subject to future subordination and the
Company does
not have a substantial continuing involvement with the new home, and (2)
land sales when
Diane Bessette
LENNAR CORP
May 16, 2019
Page 2
a significant down payment is received, the earnings process is
complete, title passes and
collectability of the receivable is reasonably assured. It is unclear
to us how these
policies comply with the provisions of ASC 606. Furthermore, we could
not locate
disclosure about the nature and timing of recognition of your
service-related performance
obligations (e.g., management fees and mortgage financing, title
insurance, and closing
service fees). Please disclose in future Forms 10-Q for the interim
periods in the fiscal
year ended November 30, 2019 your accounting policies for contracts
with customers
across all your segments.
Form 10-K for the period ended November 30, 2018
Management's Discussion and Analysis of Financial Condition and Results of
Operations
Results of Operations, page 24
2. We note your response to comment 2 from our letter dated May 1, 2019.
We believe that
the quantification of the dollar impact of the CalAtlantic acquisition
within MD&A allows
for a thorough understanding and evaluation of your operating results
for the periods
presented including any impact from organic operating results. Please
expand
your MD&A to include the information you highlight in paragraph 3 of
your response
and include similar information to the extent that the CalAtlantic
acquisition materially
impacted any additional segment results of operations.
In closing, we remind you that the company and its management are
responsible for the
accuracy and adequacy of their disclosures, notwithstanding any review,
comments, action or
absence of action by the staff.
You may contact Ameen Hamady at 202-551-3891 or in his absence, Jeanne
Baker at
202-551-3691 with any questions.
Sincerely,
FirstName LastNameDiane Bessette
Division of
Corporation Finance
Comapany NameLENNAR CORP
Office of
Manufacturing and
May 16, 2019 Page 2 Construction
FirstName LastName