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United States securities and exchange commission logo
June 1, 2020
Patrick D. Hallinan
Chief Financial Officer
Fortune Brands Home & Security, Inc.
520 Lake Cook Road
Deerfield, Illinois 60015-5611
Re: Fortune Brands Home
& Security, Inc.
Form 10-K for the
year ended December 31, 2019
Filed February 26,
2020
File No. 001-35166
Dear Mr. Hallinan:
We have reviewed your filing and have the following comment. In
our comment, we
may ask you to provide us with information so we may better understand
your disclosure.
Please respond to this comment 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
comment applies to your facts and circumstances, please tell us why in
your response.
After reviewing your
response to this comment, we may have additional comments.
Form 10-K for the year ended December 31, 2019
Item 8. Financial Statements and Supplementary Data
6. Goodwill and Identifiable Intangible Assets, page 41
1. We note you calculated
the fair value of certain trade names in 2019 and 2018 for your
impairment evaluation.
Please tell us how you determined it was not necessary to provide
quantitative
information about the significant unobservable inputs used in the fair value
measurement of these
assets. Please refer to ASC 820-10-50-2(bbb).
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 Paul Cline at 202-551-3851 or Jennifer Monick at
202-551-3295 if you
have questions regarding the comment.
Patrick D. Hallinan
Fortune Brands Home & Security, Inc.
June 1, 2020
Page 2
FirstName LastNamePatrick D. Hallinan Sincerely,
Comapany NameFortune Brands Home & Security, Inc.
Division of Corporation
Finance
June 1, 2020 Page 2 Office of Real Estate &
Construction
FirstName LastName