December 27, 2024

Johann Tse
Chief Executive Officer
Broad Capital Acquisition Corp
6208 Sandpebble Ct.
Dallas, TX 75254

       Re: Broad Capital Acquisition Corp
           Preliminary Proxy Statement on Schedule 14A
           Filed December 19, 2024
           Revised Preliminary Proxy Statement on Schedule 14A
           Filed December 20, 2024
           File No. 001-41212
Dear Johann Tse:

       We have reviewed your filings and have the following comment.

       Please respond to this letter 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 a
comment applies to your facts and circumstances, please tell us why in your
response.

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

Revised Preliminary Proxy Statement on Schedule 14A filed December 20, 2024
Risk Factors, page 23

1.     We note that you are seeking to extend your termination date to January
13, 2026, a
       date which is 48 months from your initial public offering. We also note
that you are
       currently listed on Nasdaq and that Nasdaq Rule 5815 was amended
effective October
       7, 2024 to provide for the immediate suspension and delisting upon
issuance of a
       delisting determination letter for failure to meet the requirement in
Nasdaq Rule IM
       5101-2(b) to complete one or more business combinations within 36 months
of the
       date of effectiveness of its IPO registration statement. Please revise
to state that your
       securities will face immediate suspension and delisting action once you
receive a
       delisting determination letter from Nasdaq after the 36-month window
ends on
       January 13, 2025. Please disclose the risks of non-compliance with this
rule, including
       that under the new framework, Nasdaq may only reverse the determination
if it finds
       it made a factual error applying the applicable rule. In addition,
please disclose any
 December 27, 2024
Page 2

       potential impact on your ability to complete an initial business
combination, including
       any provision of your merger agreement with Openmarkets. Please also
describe any
       impact on the market for your securities, including demand for your
securities.
        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.

      Please contact Ronald (Ron) E. Alper at 202-551-3329 or Mary Beth Breslin
at 202-
551-3625 with any questions.



                                                            Sincerely,

                                                            Division of
Corporation Finance
                                                            Office of Real
Estate & Construction
cc:   Andy Tucker