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                             October 17, 2023

       James Britton
       Executive Vice President and Chief Financial Officer
       First Foundation Inc.
       200 Crescent Court, Suite 1400
       Dallas, Texas 75201

                                                        Re: First Foundation
Inc.
                                                            Form 10-Q for the
quarterly period ended June 30, 2023
                                                            Filed August 8,
2023
                                                            File No. 001-36461

       Dear James Britton:

            We have conducted a limited review of your quarterly report and
have the following
       comments.

              Please respond to this letter 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 a
       comment applies to your facts and circumstances, please tell us why in
your response.

                                                        After reviewing your
response to this letter, we may have additional comments.

       Form 10-Q for quarterly period ended June 30, 2023

       Deposits, page 48

   1.                                                   We note disclosure that
as of June 30, 2023 you held $2.2 billion of brokered deposits,
                                                        mostly comprised of
certificates of deposit, compared to $1.3 billion of brokered deposits
                                                        as of December 31, 2022
as disclosed on page 55 of your Form 10-K for the fiscal year
                                                        ended December 31,
2022. To the extent material, please revise future filings, beginning
                                                        with your September 30,
2023 Form 10-Q, to provide additional quantitative and
                                                        qualitative information
explaining any material changes in your deposit base, such as
                                                        increased reliance on
brokered deposits, and the related impact on your funding costs and
                                                        liquidity. Please also
discuss any factors driving such an increase in utilizing brokered
                                                        deposits as a source of
funding. Please provide us with your proposed disclosures.
   2.                                                   We note the discussion
on page 23 of your Form 10-K for the fiscal year ended December
                                                        31, 2022 regarding the
five largest bank depositors accounting for 20% of your total
                                                        deposits. Please revise
future filings, beginning with your September 30, 2023 Form 10-Q,
                                                        to identify and
describe significant concentrations in deposits or advise us why you
 James Britton
FirstName  LastNameJames  Britton
First Foundation Inc.
Comapany
October  17,NameFirst
             2023     Foundation Inc.
October
Page  2 17, 2023 Page 2
FirstName LastName
         believe such disclosure is not important to an understanding of your
liquidity and material
         events and uncertainties. Please provide us with your proposed
disclosures.
Item 2. Management's Discussion and Analysis of Financial Condition and Results
of Operations
Loans, page 48

3.       We note your disclosure on page 21 of your Form 10-K for the fiscal
year ended
         December 31, 2022 indicating that your loans are geographically
concentrated. Please
         revise your Management's Discussion and Analysis in future filings,
beginning with your
         September 30, 2023 Form 10-Q, to address your geographic loan
concentrations. Please
         also revise future filings to disclose any significant loan
concentrations subject to higher
         credit risk and how you are managing the risk and exposure. In this
regard, we note the
         statement from your June 30, 2023 quarterly earnings call that you
have very little to no
         exposure to construction, hotels or commercial office space.    Please
provide us with your
         proposed disclosures.
Liquidity, page 53

4.       We note disclosure in separate sections of your filing regarding
sources of liquidity (e.g.,
         discussion of unused borrowing capacity on pages 28-29). Please revise
future filings,
         beginning with your September 30, 2023 Form 10-Q, to further clarify
your available
         sources of liquidity. Consider including tabular disclosure,
separately by type of
         borrowing capacity and showing total borrowing capacity, less
borrowings outstanding, to
         arrive at remaining capacity and then adding other sources of
liquidity (i.e. cash and cash
         equivalents, securities) to arrive at total available liquidity.
Please also discuss any
         parameters to access any borrowing capacity, as applicable. Please
provide us with your
         proposed disclosures.
Managements Discussion and Analysis of Financial Condition and Results of
Operations
Liquidity, page 53

5.       We note your disclosure that you monitor your liquidity in accordance
with guidelines
         established by your Board of Directors, as well as your reference to
your disclosure in
         your Annual Report on Form 10-K for fiscal year ended December 31,
2022. We note
         you state on page 61 of your Form 10-K that "The Board of Directors of
FFB approves
         policies and limits governing the management of interest rate risk"
and that "The asset /
         liability committee formed by these policies is responsible for
monitoring our interest rate
         risk and providing periodic reports to the Board of Directors
regarding our compliance
         with these policies and limits." Please revise future filings to
include a materially
         complete description of how you seek to manage risks due to changes in
interest rates and
         other material impacts on your operational facts and circumstances,
including any
         management or corporate governance controls or procedures for
identifying and
         responding to rapid changes in interest rates due to or as a result of
exogenous or
         unknown factors. For example, please describe the Board of Directors'
established
 James Britton
FirstName  LastNameJames  Britton
First Foundation Inc.
Comapany
October  17,NameFirst
             2023     Foundation Inc.
October
Page  3 17, 2023 Page 3
FirstName LastName
         liquidity guidelines and the Board of Directors' approved policies and
limits governing
         management of interest rate risk. In addition, indicate whether you
were in compliance
         with the guidelines, policies and limits. If not in compliance,
discuss any planned actions
         to be taken to reestablish compliance. Please revise your future
filings, beginning with
         your September 30, 2023 Form 10-Q, to include an enhanced discussion
of your liquidity
         policy guidelines and metrics used to manage your liquidity, such as
different types of
         funding or coverage ratios. Please also disclose compliance with each
of these guidelines
         and metrics, or in the event of non-compliance, disclose any planned
actions to ensure
         compliance. Please provide us with your proposed disclosures.
Item 3. Quantitative and Qualitative Disclosures about Market Risk, page 56

6.       We note your disclosure that there have been no material changes to
your quantitative and
         qualitative disclosures about market risk since December 31, 2022.
Given the recent
         banking industry issues, the current economic environment, and your
continued net
         interest margin compression during the three and six-months ended June
30, 2023 as
         disclosed on pages 38-39, please revise future filings, beginning with
your September 30,
         2023 Form 10-Q, to provide material updates to your interest rate risk
disclosures (i.e.
         Gap Analysis, Net Interest Income Simulations, Economic Value of
Equity Calculations)
         similar to the disclosures provided in your Form 10-K for the fiscal
year ended December
         31, 2022. Please ensure that your revised disclosures include a
discussion of the key
         assumptions (e.g., future balance sheet composition, loan and deposit
repricing,
         assumptions related to the magnitude of asset prepayments, earlier
than anticipated
         deposit withdrawals, etc.) for each of these interest rate risk
disclosures and a discussion
         of any changes in these key assumptions from period to period along
with the factors
         driving these changes. Refer to Item 305(a)(1)(ii)(B) of Regulation
S-K. Please provide us
         with your proposed disclosures.
7.       We note disclosure on page 61 of your Form 10-K for the fiscal year
ended December 31,
         2022 that the Board of Directors approves policies and limits
governing the management
         of interest rate risk and that the asset/liability committee formed by
these policies is
         responsible for monitoring your interest rate risk and providing
periodic reports to the
         Board of Directors regarding compliance with these policies and
limits. Please revise
         future filings, beginning with your September 30, 2023 Form 10-Q, to
include a similar
         discussion enhanced to include a more detailed description of such
material policies, the
         limits governing your management of interest rate risk, a discussion
of the
         material information the asset/liability committee gains from these
analyses (i.e. Gap
         Analysis, Net Interest Income Simulations, Economic Value of Equity
Calculations), and
         any limitations of using these analyses. Additionally, to the extent
there are significant
         changes in the outputs from these analysis from period to period,
please discuss the factors
         driving the change(s). Please provide us with your proposed
disclosures.

       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
 James Britton
First Foundation Inc.
October 17, 2023
Page 4

action by the staff.

       Please contact John Spitz at 202-551-3484 or Ben Phippen at 202-551-3697
if you have
questions regarding comments on the financial statements and related matters.
Please contact
Todd Schiffman at 202-551-3491 or Susan Block at 202-551-3210 with any other
questions.



FirstName LastNameJames Britton                           Sincerely,
Comapany NameFirst Foundation Inc.
                                                          Division of
Corporation Finance
October 17, 2023 Page 4                                   Office of Finance
FirstName LastName