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                              November 9, 2021

       Johann Tse
       Chief Executive Officer
       Broad Capital Acquisition Corp
       5345 Annabel Lane
       Plano, TX 75093

                                                        Re: Broad Capital
Acquisition Corp
                                                            Amendment No. 2 to
Registration Statement on Form S-1
                                                            Filed October 22,
2021
                                                            File No. 333-258943

       Dear Mr. Tse:

              We have limited our review of your registration statement to
those issues we have
       addressed in our 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.

       Amendment No. 2 to Registration Statement on Form S-1 filed October 22,
2021

       Cover Page

   1.                                                   We note the disclosure
on your prospectus cover page that you "believe that [you] are
                                                        currently not required
to obtain permission [from] PRC authorities to invest in, acquire or
                                                        merge with a
drone-related manufacturing company in the PRC under the authority of
                                                        legislative
developments promoting foreign investment in these asset classes." Please
                                                        expand your disclosure
to clarify whether you are required to obtain any approvals to
                                                        operate and offer
securities to foreign investors, whether you have received such
                                                        approvals and the
consequences to you and your investors if you do not receive or
                                                        maintain the approvals,
inadvertently conclude that such approvals are not required, or
                                                        applicable laws,
regulations, or interpretations change and you are required to obtain
                                                        approval in the future.
We note your new risk factor on page 60.
 Johann Tse
Broad Capital Acquisition Corp
November 9, 2021
Page 2


Potential Consequences of the Holding Foreign Companies Accountable Act, page
18

2.    Revise to also disclose that in June 2021, the United States Senate
passed the Accelerating
      Holding Foreign Companies Accountable Act, which, if enacted, would
decrease the
      number of non-inspection years from three years to two, thus reducing the
time period
      before your securities may be prohibited from trading or delisted. Please
also update the
      related risk factor on page 61 accordingly.

Summary of Risk Factors, page 32

3.    We reissue prior comment 4. Please provide enhanced cross-references to
the more
      detailed discussion of the previously referenced risks in the prospectus.
Similarly, please
      include in the Summary of Risk Factors the previously requested
acknowledgement that
      any actions by the Chinese government to exert more oversight and control
over offerings
      that are conducted overseas and/or foreign investment in China-based
issuers
      could significantly limit or completely hinder your ability to offer or
continue to offer
      securities to investors and cause the value of such securities to
significantly decline or be
      worthless. We note the related disclosures at page 57 under "If we enter
into a business
      combination in China" and page 68 under "The Chinese government may
intervene or
      influence the operations of a target 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.

       You may contact Timothy S. Levenberg, Special Counsel, at (202)
551-3707, or Loan
Lauren Nguyen, Legal Branch Chief, at (202) 551-3642 with any questions.



                                                             Sincerely,
FirstName LastNameJohann Tse
                                                             Division of
Corporation Finance
Comapany NameBroad Capital Acquisition Corp
                                                             Office of Energy &
Transportation
November 9, 2021 Page 2
cc:       Debbie Klis, Esq.
FirstName LastName