May 30, 2019

Christopher Farrar
Chief Executive Officer
Velocity Financial, LLC
30699 Russell Ranch Road
Suite 295
Westlake Village, CA 91362

       Re: Velocity Financial, LLC
           Amendment No. 1 to Draft Registration Statement on Form S-1
           Submitted May 9, 2019
           CIK No. 0001692376

Dear Mr. Farrar:

      We have reviewed your amended draft registration statement 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 this letter by providing the requested information and
either submitting
an amended draft registration statement or publicly filing your registration
statement on
EDGAR. If you do not believe our comments apply to your facts and circumstances
or do not
believe an amendment is appropriate, please tell us why in your response.

      After reviewing the information you provide in response to these comments
and your
amended draft registration statement or filed registration statement, we may
have additional
comments.

DRS/A submitted on May 9, 2019

Cover Page

1.     We note your response to comment 3 of our letter. Please note that we
have referred your
       response to the Division of Investment Management for further review and
they will
       contact you directly when they have completed their review. Please feel
free to contact
       the Division of Investment Management staff member referenced below
regarding their
       review
2.     Please revise footnote 4 to clarify that the portfolio yield figure
excludes general company
       expenses, such as cost of funds. Please also tell us, with a view toward
disclosure,
       whether the origination growth figure includes instances where the
company refinances
 Christopher Farrar
FirstName LastNameChristopher Farrar
Velocity Financial, LLC
Comapany NameVelocity Financial, LLC
May 30, 2019
May 30, 2019 Page 2
Page 2
FirstName LastName
         existing loans.
Risk Factors, page 18

3.       We note your response to comment 9 of our letter. We note that there
is no
         minimum credit score that a potential borrower must have in order to
obtain a loan. Please
         tell us what consideration you gave to including risk factor
disclosure addressing related
         risks.
We use leverage in executing our business strategy..., page 22

4.       We note your response to comment 4 of our letter. In response to our
comment, you state
         that two warehouse repurchase facilities include financial covenants
limiting your ability
         to leverage your assets. Please quantify the maximum debt-to-net-worth
ratio contained in
         your repurchase facilities. Please also clarify if there is any limit
on the amount of
         leverage you may incur in your corporate documents.
Dilution, page 50

5.       Please clarify that the historical pro forma net tangible book value
per share as of
         December 31, 2018, after giving effect to the Conversion but before
giving effect to this
         offering, includes the restricted shares of common stock that will be
issued upon
         conversion of Class B units, as described on page 133. In this regard,
Item 506 of
         Regulation S-K requires a comparison of the public offering price and
the effective cash
         cost to officers, directors, promoters, and affiliated persons for
shares acquired by them,
         or that they have a right to acquire. Please also confirm that the
common stock to be
         outstanding upon completion of this offering, as disclosed throughout
the prospectus,
         includes such shares.
Management's Discussion and Analysis of Financial Condition and Results of
Operations, page
54

6.       We note you have identified a material weakness in your internal
control over financial
         reporting. Please revise your Management's Discussion and Analysis of
Financial
         Condition and Results of Operations to disclose information
surrounding the material
         weakness identified and to disclose the specific steps you are taking
to remediate this
         material weakness.
Key Performance Metrics, page 66

7.       We note your disclosure of pre-tax return on adjusted equity. Please
tell us how you
         determined that a metric that excludes taxes represents a return on
adjusted equity.
 Christopher Farrar
Velocity Financial, LLC
May 30, 2019
Page 3
Executive Compensation
Summary Compensation Table, page 139

8.    Please provide 3 years of disclosure in the compensation table in
accordance with Item
      402(c) of Regulation S-K.
Audited Consolidated Financial Statements, page F-2

9.    We note your response to prior comment 11. We believe that the
information required by
      Rule 12-29 of Regulation S-X is applicable to your business. Please
include Schedule IV
      in future amendments to your filing.


       You may contact Peter McPhun at 202-551-3581 or Jennifer Monick,
Assistant Chief
Accountant, at 202-551-3295 if you have questions regarding comments on the
financial
statements and related matters. Please contact Stacie Gorman at 202-551-3585 or
Kim Mcmanus
at 202-551-3215 with any other questions.



                                                          Sincerely,

FirstName LastNameChristopher Farrar                      Division of
Corporation Finance
                                                          Office of Real Estate
and
Comapany NameVelocity Financial, LLC
                                                          Commodities
May 30, 2019 Page 3
cc:       Daniel N. Webb, Esq.
FirstName LastName