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                             August 20, 2020

       Chan Heng Fai
       Chairman and Chief Executive Officer
       HF Enterprises Inc.
       4800 Montgomery Lane
       Suite 210
       Bethesda MD 20814

                                                        Re: HF Enterprises Inc.
                                                            Amendment No. 1 to
Form S-1
                                                            Filed July 30, 2020
                                                            File No. 333-235693

       Dear Mr. Heng Fai:

             We have reviewed your amended 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 amending your registration
statement and providing the
       requested information. 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 any amendment to your registration statement and
the information you
       provide in response to these comments, we may have additional comments.
Unless we note
       otherwise, our references to prior comments are to comments in our
January 13, 2020 letter.

       Form S-1/A filed July 30, 2020

       Note 3. Summary of Significant Accounting Policies
       Sale of the Front Foot Benefit Assessments, page F-15

   1.                                                   Please revise to
disclose the amount of revenue from the front foot benefit assessment that
                                                        you have recognized
from homeowners and sales of the collection rights to investors.
                                                        Also, revise to clarify
whether these assessments are subject to amendment by regulatory
                                                        agencies. This comment
also applies to the fiscal year financial statements.
 Chan Heng Fai
HF Enterprises Inc.
August 20, 2020
Page 2
Note 17. Subsequent Events
Changes of Ownership Percentage of SeD Ltd, page F-34

2.    We note your disclosure that the Company   s ownership interest in SeD
Ltd changed from
      65.4% as of March 31, 2020 to 49.1% as of July 30, 2020. Please tell us
how you will
      account for this loss of control over SeD Ltd and the guidance upon which
you relied.
      Also, tell us whether SeD Ltd has outstanding warrants or other equity
rights held by other
      parties that could further reduce your ownership interest in this entity
if they were
      exercised. This comment also applies to the fiscal year financial
statements.
Planned Reorganization of Certain Biohealth Activities, page F-34

3.    Please tell us how you will account for the share exchange agreement with
DSS relating to
      the reorganization of your Biohealth entities and the guidance upon which
you relied.
       You may contact Jorge Bonilla at 202-551-3414 or Daniel Gordon at
202-551-3486 if
you have questions regarding comments on the financial statements and related
matters. Please
contact Stacie Gorman at 202-551-3585 or Sonia Barros at 202-551-3655 with any
other
questions.



                                                           Sincerely,
FirstName LastNameChan Heng Fai
                                                           Division of
Corporation Finance
Comapany NameHF Enterprises Inc.
                                                           Office of Real
Estate & Construction
August 20, 2020 Page 2
cc:       Spencer G. Feldman, Esq.
FirstName LastName