October 30, 2018

Raymond S. Lopez
Chief Financial Officer
BBX Capital Corporation
401 East Las Olas Boulevard
Suite 800
Fort Lauderdale, FL 33301

       Re: BBX Capital Corporation
           Form 10-K for Fiscal Year Ended December 31, 2017
           Filed March 9, 2018
           Form 10-Q for Fiscal Quarter Ended June 30, 2018
           Filed August 6, 2018
           File No. 001-09071

Dear Mr. Lopez:

       We have limited our review of your filing to the financial statements
and related
disclosures 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.

Form 10-K for Fiscal Year Ended December 31, 2017

Item 1. Business
Project Portfolio, page 20

1.     We note you have provided expected exit/sales dates and estimated future
proceeds for
       your investments. While we note your footnote explaining the limitations
to these
       projections, we did not note any disclosure stating your basis for these
projections or any
       significant assumptions used. As such please tell us why you believe
your projections
       comply with the Commission Policy on Projections in Item 10(b) of
Regulation S-K.
 Raymond S. Lopez
BBX Capital Corporation
October 30, 2018
Page 2
Item 9A. Controls and Procedures
Management's Report on Internal Control Over Financial Reporting, page 91

2.       We note that your management report does not include a statement that
your registered
         public accounting firm issued an attestation report. Refer to Item
308(a)(4) of Regulation
         S-K and revise future filings as necessary.
Item 8. Financial Statements
6. Notes Receivable, page F-30

3.       Please tell us how you determined it was unnecessary to disclose
quantitative information
         by credit quality indicator. Reference is made to ASC 310-10-50-29.
Form 10-Q for Fiscal Quarter Ended June 30, 2018

2. Revenue Recognition, page 13

4.       Please tell us how you determined it was unnecessary to disclose the
significant payment
         terms for your performance obligations. Reference is made to ASC
606-10-50-12(b).
         Please include this information in future periodic filings as
necessary.


5.       Please tell us how you determined it was unnecessary to disclose the
amount of the
         transaction price allocated to unsatisfied performance obligations and
to provide an
         explanation of when this amount will be recognized as revenue. Refer
to ASC 606-10-50-
         13. Please include this information in future periodic filings as
necessary.
       In closing, 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.

       You may contact Babette Cooper, Staff Accountant, at 202-551-3396 or
Jennifer Monick,
Assistant Chief Accountant, at 202-551-3295 with any questions.



                                                              Sincerely,
FirstName LastNameRaymond S. Lopez
                                                              Division of
Corporation Finance
Comapany NameBBX Capital Corporation
                                                              Office of Real
Estate and
October 30, 2018 Page 2                                       Commodities
FirstName LastName