Mail Stop 3233
                                                            March 26, 2019

Via E-mail
John C. Loeffler, II
Chief Executive Officer and Chairman of the Board
CaliberCos Inc.
8901 E. Mountain View Road
Suite 150
Scottsdale, AZ 85258

       Re:     CaliberCos Inc.
               Amendment No. 3 to Draft Offering Statement on Form 1-A
               Submitted March 4, 2019
               CIK No. 0001627282

Dear Mr. Loeffler:

       We have reviewed your amended draft registration statement and have the
following
comment. In our comment, we may ask you to provide us with information so we
may better
understand your disclosure.

       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 our 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 comment
and your
amended draft registration statement or filed registration statement, we may
have additional
comments.

General

1.     On page 78 you state that you "expect to use a significant majority of
the net proceeds
       from this offering to invest and hold at least 55% of [y]our investment
subsidiaries' total
       assets in commercial real estate loans." This description of how you
will use proceeds is
       inconsistent with your use of proceeds discussion on page 22. In
addition, your overall
       business discussion gives the impression that you will directly invest
in real estate, as
       opposed to real estate loans, and therefore is also inconsistent with
the statement
       referenced on page 78. Please revise to ensure consistency.
 John C. Loeffler, II
Chief Executive Officer and Chairman of the Board
CaliberCos Inc.
March 26, 2019
Page 2

        You may contact Kristi Marrone at (202)551-3429 or Kevin Woody,
Accounting Branch
Chief, at (202)551-3629 if you have questions regarding comments on the
financial statements
and related matters. Please contact Stacie Gorman at (202)551-3585 or me at
(202)551-3215
with any other questions.

                                                         Sincerely,

                                                         /s/ Kim McManus

                                                         Kim McManus
                                                         Senior Counsel
                                                         Office of Real Estate
and
                                                         Commodities
cc: Thomas Poletti, Esq. (via e-mail)