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                               November 22, 2022

       Joseph W. Turner
       Chief Executive Officer
       Ministry Partners Investment Company, LLC
       915 West Imperial Highway, Suite 120
       Brea, California 92821

                                                        Re: Ministry Partners
Investment Company, LLC
                                                            Post-Effective
Amendment No. 1 to Registration Statement on Form S-1
                                                            Filed October 28,
2022
                                                            File No. 333-250027

       Dear Joseph W. Turner:

              We have reviewed your post-effective amendment 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 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.

       Post-Effective Amendment No. 1 to Registration Statement on Form S-1

       General

   1.                                                   This post-effective
amendment was filed in part to update the financial information in
                                                        your registration
statement on Form S-1, which last contained audited financial statements
                                                        for the fiscal year
ended December 31, 2019. Under Section 10(a)(3) of the Securities Act
                                                        of 1933, "when a
prospectus is used more than nine months after the effective date of the
                                                        registration statement,
the [audited financial] information contained therein shall be as of a
                                                        date not more than
sixteen months prior to such use." Please tell us whether you engaged
                                                        in any offers or sales
of your securities using the prospectus after October 8, 2021.
   2.                                                   Please revise this
post-effective amendment to include the information required
                                                        by Part II of Form S-1.
 Joseph W. Turner
Ministry Partners Investment Company, LLC
November 22, 2022
Page 2
Cover Page

3.    We note your disclosure in the Explanatory Note that one purpose of this
post-effective
      amendment is to "permit the spread adjustment used to determine the
interest rate for a
      Fixed or Variable Debt Certificate to be adjusted by up to 250 basis
points when rapid
      changes in interest rates or market changes occur." We also note that in
your earlier
      disclosure in the question and answer section on page 4 of the
registration statement on
      Form S-1 filed on January 8, 2021 (file No. 333-250027) and in your
response to our
      comment regarding such disclosure, you undertook to keep any interest
rate changes to a
      narrower specified range (within 200 basis points for the Fixed Spread
and 100 basis
      points for the Variable Spread Grid). Because you previously stated
interest rate changes
      would be limited to a certain range but now increased that range,
disclose whether there is
      a limit to the amount or number of times you plan to increase or decrease
rates. Please
      also provide us with your legal analysis of whether the offering will be
a delayed offering
      under Rule 415 of the Securities Act. We note that it appears you are not
eligible to
      conduct a delayed offering pursuant to Rule 415.
        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 Robert Arzonetti at 202-551-8819 or Tonya K. Aldave at
202-551-3601
with any other questions.



                                                           Sincerely,
FirstName LastNameJoseph W. Turner
                                                    Division of Corporation
Finance
Comapany NameMinistry Partners Investment Company, LLC
                                                    Office of Finance
November 22, 2022 Page 2
cc:       Randy Sterns, Esq.
FirstName LastName