Mail Stop 4561
	 								July 13, 2006

VIA U.S. MAIL AND FAX (248) 208-2640

Mr. Gary A. Shiffman
Chief Executive Officer
Sun Communities, Inc.
27777 Franklin Road, Suite 200
Southfield, MI 48034

      Re:	Sun Communities, Inc
      	Form 10-Q for the quarter ended March 31, 2006
      	Filed May 10, 2006
      File No. 333-72461

Dear Mr. Shiffman:

      We have reviewed the above referenced filing and have the
following comments.  We have limited our review of your filing to
the
issue we have addressed in our comments.  After reviewing this
information we may raise additional comments.

	Please understand that the purpose of our review process is
to
assist you in your compliance with the applicable disclosure
requirements and to enhance the overall disclosure in your filing.
We look forward to working with you in these respects.  We welcome
any questions you may have about our comments or on any other
aspect
of our review.  Feel free to call us at the telephone numbers
listed
at the end of this letter.

Note 12 - Contingencies

1. You disclose that the Order does not impose any monetary
penalties, nor do the terms of the Order require the Company to
restate any of its prior financial statements.  However, we note
that
the company agreed to a cease and desist order that states your
financial statements are materially misstated and lists the
amounts
and percentages of the misstatements.  Please tell us why you did
not
disclose the findings of the Enforcement division related to the
material misstatement of your prior financial statements and
provide
an explanation to investors as to why the company does not believe
it
should restate its financial statements in light of those
findings.

2. Also, provide us with a draft of your disclosure that addresses
the above stated concerns that you will include in the company`s
upcoming filing or in an amended March 31, 2006 10-Q.  If you
believe
no restatement is required, including a restatement of the
Selected
Financial Data for 2002 and 2001, explain the basis for that
conclusion to us and include sufficient specificity of the nature
and
amount of each error and a materiality analysis for the errors,
individually and in the aggregate.

*    *    *    *

      Please respond to these comments within 10 business days or
tell us when you will provide us with a response.  Please furnish
a
letter that keys your response to our comments.  Please understand
that we may have additional comments after reviewing your response
to
our comments.

            We urge all persons who are responsible for the
accuracy
and adequacy of the disclosure in the filing to be certain that
they
have provided all information required under the Securities
Exchange
Act of 1934 and that they have provided all information investors
require for an informed investment decision.  Since the company
and
its management are in possession of all facts relating to a
company`s
disclosure, they are responsible for the accuracy and adequacy of
the
disclosures they have made.

            In connection with responding to our comments, please
provide, in writing, a statement from the company acknowledging
that

?        the company is responsible for the adequacy and accuracy
of
the disclosure in the filing;

?        staff comments or changes to disclosure in response to
staff
comments do not foreclose the Commission from taking any action
with
respect to the filing; and

?        the company may not assert staff comments as a defense in
any proceeding initiated by the Commission or any person under the
federal securities laws of the United States.

      In addition, please be advised that the Division of
Enforcement
has access to all information you provide to the staff of the
Division of Corporation Finance in our review of your filings or
in
response to our comment on your filing.


You may contact Eric McPhee, Staff Accountant, at (202) 551-3693
or
me at (202) 551-3486 with any questions.


Sincerely,



Daniel L. Gordon
Branch Chief


Mr. Gary A. Shiffman
Sun Communities, Inc.
July 13, 2006
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