August 12, 2024

Scott F. Kavanaugh
Chief Executive Officer
First Foundation Inc.
200 Crescent Court
Suite 1400
Dallas, Texas 75201

       Re: First Foundation Inc.
           Preliminary Proxy Statement on Schedule 14A
           File July 29, 2024
           File No. 001-36461
Dear Scott F. Kavanaugh:

       We have reviewed your filing 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.

Preliminary Proxy Statement on Schedule 14A
Question and Answers About the Special Meeting, page 2

1.     Revise this section to provide a question and answer that addresses the
essential reasons
       that you are conducting the Special Meeting. In particular, refer to the
July capital raise,
       including the amount sold, the implied per-share cost and the fact that
the transaction will
       substantially dilute existing shareholders.
Summary of the July 2024 Capital Raise
The July 2024 Capital Raise, page 5

2.     Revise this section, or another appropriate section, to explain in
greater detail the reasons
       that the Board of First Foundation determined to engage in this capital
increase, a
       transaction that effectively resulted in a change in control of the
registrant. In particular,
       discuss any and all capital, operating or lending limitations that
impacted the Board and
       management's decision to enter into the transaction. For instance,
discuss the extent to
       which your commercial real estate loans exceeded regulatory guidelines,
your losses in
 August 12, 2024
Page 2

       2023 and 2024, and the health of your multifamily portfolio. Your
shareholders must be
       able to understand why the Board agreed to enter into the capital raise.
3.     We note your disclosure that you believe the proceeds from July 2024
capital raise will
       provide you with the financial strength and flexibility to strengthen
your balance sheet
       and aid in profitably building your deposit base, loan portfolio and
high-performing
       wealth management business across markets. Provide investors with
additional
       information on your current operating strategy that you will implement
as a result of the
       capital raise, including any changes to how you plan to run your
business. Please refer to
       Item 11(c)(2) disclosure and clarify whether the proceeds from the
capital raise are
       necessary to meet those goals.
4.     Revise your disclosure in this section to compare the implied per-share
purchase price
       paid by the investors in the capital raise to the trading price of First
Foundation's shares in
       the day prior to the public announcement.
5.     Please tell us why you did not provide the financial information
required by Item 13(a)
       under Items 11 of Schedule 14A. In particular, please provide your
analysis as to how you
       concluded that financial statements are not necessary for the exercise
of prudent
       judgment. We note that the underlying capital raise transaction involved
the sale of
       preferred shares convertible into common for a value substantially below
the existing
       market price. We also note that the transactions will result in the sale
of a controlling
       interest in the company.
Board of Directors Reconstitution , page 9

6.     Revise this section to discuss the extent to which the purchasers in the
capital raise
       nominated or participated in the selection of either the new executive
officer or any of the
       new members of the Board. Discuss any provisions of the investment
agreements that
       give any of the investor groups individually, or collectively, the right
to representation on
       the Board, or the right to nominate Board members.
        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.

       Please contact Aisha Adegbuyi at 202-551-8754 or Christian Windsor at
202-551-3419
with any other questions.



                                                              Sincerely,

                                                              Division of
Corporation Finance
                                                              Office of Finance