November 1, 2024

Jay J. Jackson
President and CEO
Abacus Life, Inc.
2101 Park Center Drive, Suite 200
Orlando, FL 32835

        Re: Abacus Life, Inc.
            Post-Effective Amendment No. 1 to Registration Statement on Form
S-1 on
            Form S-3
            Filed October 21, 2024
            File No. 333-273411
Dear Jay J. Jackson:

       We have conducted a limited review of your registration statement and
have the
following comments.

        Please respond to this letter by amending your registration statement
and providing
the requested information. If you do not believe a comment applies 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 this letter, we may have additional comments.

Post-Effective Amendment No. 1 to Form S-1 on Form S-3 filed October 21, 2024
General

1.     We note the risk factors on pages 11, 13, and 20 of your annual report
on Form 10-
       K/A for the fiscal year ended December 31, 2023 ("Annual Report"), which
you
       incorporate by reference, implying that valuations of life insurance
policies are key to
       your business. We also note your disclosure on page 7 of your Annual
Report
       describing your partnership with Lapetus Solutions, Inc. ("Lapetus").
Please tell us
       whether Abacus or any of its officers, directors or other affiliates,
have an ownership
       interest or credit relationship in Lapetus or its subsidiaries or other
affiliates. Please
       provide a detailed explanation of any relationship and disclose the
extent to which you
       have relied upon Lapetus or any of its co-owned entities for valuation
of life insurance
       policies that you have purchased for your own account or which you have
facilitated
 November 1, 2024
Page 2

       the purchase by other entities or investors. Consider revising your risk
factor
       disclosure based on your response.
2.     If Lapetus is a related party, discuss any limitations on your ability
to rely on Lapetus
       to value life insurance policies under any relevant state laws governing
the purchase
       or sale of life insurance policies of third parties, and state whether
you are in
       compliance with any such laws.
Risk Factors, page 8

3.     We note your risk factor disclosure on page 20 of your Annual Report
that you are
       reliant on your management and on page 24 of your Annual Report that
your
       executive officers have limited experience in the management of a
publicly traded
       company. We also note that National Insurance Brokerage operates at an
address in
       the same office park as Abacus. We note that the Florida Secretary of
State lists Scott
       Kirby, Matthew Ganovsky, and Sean McNealy as officers of National
Insurance
       Brokerage. Please revise your disclosure to discuss the extent to which
you purchase
       insurance contracts from National Insurance Brokerage. Also, consider
appropriate
       revisions to your risk factors to discuss the risks that management's
other business
       interests may interfere with their focus on managing your business.
        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.

       Refer to Rules 460 and 461 regarding requests for acceleration. Please
allow adequate
time for us to review any amendment prior to the requested effective date of
the registration
statement.

      Please contact Madeleine Joy Mateo at 202-551-3465 or Christian Windsor
at 202-
551-3419 with any other questions.



                                                             Sincerely,

                                                             Division of
Corporation Finance
                                                             Office of Finance
cc:   Ryan Maierson, Esq.