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                     January 11, 2021

       Jeff Whiteside
       Chief Financial Officer
       EXP World Holdings, Inc.
       2219 Rimland Drive, Suite 301
       Bellingham, WA. 98226

                                                        Re: EXP World Holdings,
Inc.
                                                            Form 10-K for the
year ended December 31, 2019
                                                            Filed on March 12,
2020
                                                            File No. 001-38493

       Dear Mr. Whiteside:

              We have completed our review of your filing. 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.




                     Sincerely,


                     Division of Corporation Finance

                     Office of Real Estate & Construction