December 19, 2018

Viki Blinderman
Senior Vice President and Principal Financial Officer
Carriage Services, Inc.
3040 Post Oak Boulevard, Suite 300
Houston, Texas, 77056

       Re: Carriage Services, Inc.
           Form 10-K for the Year Ended December 31, 2017
           Filed February 21, 2018
           Form 10-Q for the Quarterly Period Ended September 30, 2018
           Filed November 1, 2018
           File No. 001-11961

Dear Ms. Blinderman:

       We have limited our review of your filings 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.

Form 10-Q For The Quarterly Period Ended September 30, 2018

Financial Statements
Consolidated Statement of Operations, page 4

1.    State separately on the face of your income statement net sales of
tangible products and
      revenues from services, pursuant to 5-03(b)1 of Regulation S-X.
Similarly, you should
      state separately cost of tangible goods sold and cost of services,
pursuant to 5-03(b)2 of
      Regulation S-X.
2. Recently Issued Accounting Standards
Revenue Recognition, page 11

2.    Please helps us to understand the nature of your funeral and cemetery
performance
 Viki Blinderman
Carriage Services, Inc.
December 19, 2018
Page 2
         obligations. Tell us what merchandise and services you have combined
with others for the
         purpose of determining your performance obligations and which
merchandise and services
         you have treated as a separate performance obligation.
3.       Please explain to us your basis in ASC 606 for your policy of
deferring recognition of
         preneed funeral commission revenue to the point at which the
commission is no longer
         subject to refund. Specifically address your consideration of the
guidance in ASC 606-10-
         55-23 through 55-26.
4.       Please explain to us your consideration of the guidance in ASC
606-10-55-36 - 55-40
         when determining whether you are acting as a principle or as an agent
when providing
         travel protection, memorialization merchandise, and personalized
marker merchandise.
5.       Regarding your insurance funded preneed contracts, please tell us if
the beneficiary has
         committed to assign the benefits of the policy to you at the time of
need. Also, please tell
         us if you transfer any merchandise or services prior to the time of
need.
       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 Joseph M. Kempf, Senior Staff Accountant, at
202-551-3352 or Robert
S. Littlepage, Accountant Branch Chief, at 202-551-3361, with any questions.



FirstName LastNameViki Blinderman                              Sincerely,
Comapany NameCarriage Services, Inc.
                                                               Division of
Corporation Finance
December 19, 2018 Page 2                                       Office of
Telecommunications
FirstName LastName