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                             June 21, 2024

       Richard Bunch
       Chief Executive Officer
       TWFG, Inc.
       1201 Lake Woodlands Drive, Suite 4020
       The Woodlands, Texas 77380

                                                        Re: TWFG, Inc.
                                                            Amendment No. 2 to
Draft Registration Statement on Form S-1
                                                            Submitted June 3,
2024
                                                            CIK No. 0002007596

       Dear Richard Bunch:

            We have reviewed your amended draft registration statement and have
the following
       comments.

              Please respond to this letter by providing the requested
information and either submitting
       an amended draft registration statement or publicly filing your
registration statement on
       EDGAR. 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 the information you provide in response to this
letter and your amended
       draft registration statement or filed registration statement, we may
have additional
       comments. Unless we note otherwise, any references to prior comments are
to comments in our
       June 3, 2024 letter.

       Amendment No. 2 to Registration Statement on Form S-1

       Who we are, page 3

   1.                                                   We note your response
to prior comment 6. Please explain the extent to which individuals
                                                        purchasing plans enter
into agreements with the insurance carriers. Additionally, please
                                                        clarify whether your
statement that you retain 100% of the commission income received
                                                        from insurance carriers
applies solely to your Corporate Branches.
       Management's Discussion and Analysis, page 101

   2.                                                   We note the revised
disclosure on page 111, your response to comment 4, and discussion
                                                        of non-renewal of
business in "catastrophe locations, and certain insurance carriers not
                                                        accepting new business
in locations that have experienced catastrophes." Please revise to
 Richard Bunch
TWFG, Inc.
June 21, 2024
Page 2
       further clarify trends relating to such non-renewals and carriers not
accepting new
       business in locations that have experienced catastrophes. In this
regard, we note news
       reports of insurance carriers ceasing to provide insurance in states
identified on the map
       on page 7.
3.     It appears expenses attributed to Corporate Branches are significantly
lower relative
       to expenses for Agency-in-a-Box. We also note the conversion of 9
independent branches
       to Corporate Branches. Please revise to further clarify the relative
profitability of the
       Agency-in-a-Box and Corporate Branches and expand your trends disclosure
as
       appropriate.
Item 15. Recent sales of unregistered securities, page II-3

4.     We note your response to prior comment 1. Please revise your disclosure
regarding the
       January 1, 2024 issuance of common units to nine of your independent
branches to name
       the persons or identify the class of persons to whom the securities were
sold. As to any
       securities sold otherwise than for cash, state the aggregate amount of
consideration
       received by the registrant. Refer to Items 701(b) and 701(c) of
Regulation S-K.
Item 16. Exhibits and financial statement schedules, page II-4

5.     Please revise to include active links to exhibits that are filed with
the registration
       statement. Please see Item 601(a)(2) of Regulation S-K.
       Please contact John Spitz at 202-551-3484 or Marc Thomas at 202-551-3452
if you have
questions regarding comments on the financial statements and related matters.
Please contact
Madeleine Joy Mateo at 202-551-3465 or James Lopez at 202-551-3536 with any
other
questions.



                                                               Sincerely,
FirstName LastNameRichard Bunch
                                                               Division of
Corporation Finance
Comapany NameTWFG, Inc.
                                                               Office of
Finance
June 21, 2024 Page 2
cc:       Rob Shearer, Esq.
FirstName LastName