EXHIBIT 99.5

[LETTERHEAD OF CITIGROUP GLOBAL MARKETS INC.]

The Board of Directors
Pulte Homes, Inc.
100 Bloomfield Hills Parkway
Bloomfield Hills, Michigan 48304

Members of the Board:

We hereby consent to the inclusion of our opinion letter, dated April 7, 2009, to the Board of Directors of Pulte Homes, Inc. (“Pulte”) as Annex B to, and to the reference thereto under the captions “SUMMARY — Opinions of Financial Advisors — Opinion of Pulte's Financial Advisor” and “THE MERGER — Opinion of Pulte’s Financial Advisor” in, the joint proxy statement/prospectus relating to the proposed merger involving Pulte and Centex Corporation, which joint proxy statement/prospectus forms a part of the Registration Statement on Form S-4 of Pulte. By giving such consent, we do not thereby admit that we are experts with respect to any part of such Registration Statement within the meaning of the term “expert” as used in, or that we come within the category of persons whose consent is required under, the Securities Act of 1933, as amended, or the rules and regulations of the Securities and Exchange Commission promulgated thereunder.

Very truly yours,
 

/s/ Citigroup Global Markets Inc.
 

CITIGROUP GLOBAL MARKETS INC. 

May 4, 2009