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                             April 21, 2022

       Sterling Griffin
       Chief Executive Officer
       Harbor Custom Development, Inc.
       11505 Burnham Dr., Suite 301
       Gig Harbor, Washington 98332

                                                        Re: Harbor Custom
Development, Inc.
                                                            Form 8-K filed on
April 21, 2022
                                                            File No. 001-39266

       Dear Mr. Griffin:

              We have reviewed your filing 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 these comments 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 our
       comments apply to your facts and circumstances, please tell us why in
your response.

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

       Form 8-K filed on April 21, 2022

       General

   1.                                                   Please revise your
disclosure to include, in accordance with Item 4.02(a)(3), a statement
                                                        of whether the audit
committee, or the board of directors in the absence of an audit
                                                        committee, or
authorized officer or officers, discussed with the registrant   s independent
                                                        accountant the matters
disclosed in the 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.

                                                        You may contact Ameen
Hamady at 202-551-3891 with any questions.




                             Sincerely,
 Sterling Griffin
Harbor Custom Development, Inc.
April 21, 2022
Page 2
FirstName LastNameSterling Griffin
Comapany NameHarbor Custom Development, Inc.
                                               Division of Corporation Finance
April 21, 2022 Page 2                          Office of Real Estate &
Construction
FirstName LastName