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                           January 13, 2023

       Joel Markovits
       Chief Financial Officer
       Reliance Global Group, Inc.
       300 Blvd. of the Americas, Suite 105
       Lakewood, New Jersey 08701

                                                        Re: Reliance Global
Group, Inc.
                                                            Form 10-K for
Fiscal Year Ended December 31, 2021
                                                            Form 10-Q for
Fiscal Quarter Ended June 30, 2022
                                                            Response Dated
November 16, 2022
                                                            File No. 001-40020

       Dear Joel Markovits:

              We have reviewed your November 16, 2022 response to our comment
letter 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. Unless we note otherwise, our references to prior comments are
to comments in our
       October 20, 2022 letter.

       Form 10-K for Fiscal Year Ended December 31, 2021

       Note 4. Investment in NSURE, Inc., page F-20

   1.                                                   Please refer to comment
1. We note the closing date of the purchase agreement was
                                                        December 31, 2022.
Please provide us an update on the purchase, any other transactions
                                                        related to the
agreement and your accounting for the shares at December 31, 2022. Please
                                                        tell us how you
considered whether to recognize a gain related to this purchase contract
                                                        when the agreement was
entered into during the quarter ended June 30, 2022 and tell us
                                                        any accounting guidance
you considered in your determination.
 Joel Markovits
FirstName  LastNameJoel  Markovits
Reliance Global Group, Inc.
Comapany
January 13,NameReliance
            2023         Global Group, Inc.
January
Page 2 13, 2023 Page 2
FirstName LastName



Form 10-Q for Fiscal Quarter Ended June 30, 2022
Note 7. Earnings (Loss) Per Share, page 18

2.       Please refer to comment 3. Please provide us your materiality
analysis, based on the
         guidance in SAB Topic 1M, supporting your determination that the
errors in diluted EPS
         for the three and six month periods ended June 30, 2022 were
immaterial both
         quantitatively and qualitatively.
3.       Please refer to comment 3. Please revise to include the effect of the
Series B warrant
         liability in your determination of the weighted average shares, as
adjusted-denominator
         diluted computation line item for the three months ended June 30, 2022
detailed in Exhibit
         A or tell us why it should not be included.
4.       Please refer to comment 3. Please tell us if the basic or diluted
earnings per share
         disclosed in your March 31, 2022 or September 30, 2022 Forms 10-Q also
had a similar
         error. If so, please explain the error, show us the corrected
calculations and the impact of
         the error and amend the applicable Forms 10-Q to correct the error in
accordance with
         ASC 250 and consider the need to file a Form 8-K Item 4.02.
5.       Please refer to comment 4. We note your reconciliation of the weighted
average common
         shares outstanding included in the basic EPS calculation for the
three-months and six-
         months ended June 30, 2022, included in response 6 in your October 7,
2022 response
         letter. Please address the following:

                Please provide us a detailed calculation of the weighted
average common shares
              outstanding used in the basic and diluted EPS calculation for
each period disclosed in
              the March 31, 2022, June 30, 2022 and September 30, 2022 Forms
10-Q.
                Please ensure the information provided clearly details the
starting amount (e.g., the
              15,638,236 and 13,071,072 amounts previously disclosed in
response 6 in your
              October 7, 2022 response letter) and reconcile these amounts to
the common share
              amounts disclosed in the Statements of Stockholders    Equity
roll forward on page 5
              of the September 30, 2022 Form 10-Q.
                Please explain to us the basis for any material adjustment(s)
to stockholders    equity
              common share amounts.
                Please explain to us how you measured the impact, if any, of
the Series C and D
              warrants for each calculation and tell us how your treatment is
consistent with the
              guidance in ASC 260-10-S99-1 or any other relevant guidance.
 Joel Markovits
Reliance Global Group, Inc.
January 13, 2023
Page 3

       You may contact John Spitz at (202) 551-3484 or Michael Volley at (202)
551-3437 with
any questions.



FirstName LastNameJoel Markovits                         Sincerely,
Comapany NameReliance Global Group, Inc.
                                                         Division of
Corporation Finance
January 13, 2023 Page 3                                  Office of Finance
FirstName LastName