May 6, 2019

Bridgette Roman
General Counsel
CCF Holdings LLC
6785 Bobcat Way
Suite 200
Dublin, OH 43016

       Re: CCF Holdings LLC
           Registration Statement on Form S-1
           Filed April 26, 2019
           File No. 333-231069

Dear Ms. Roman:

       We have reviewed your registration statement 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.

Form S-1 filed April 26, 2019

General

1.     We note your response to comment 10 of our letter dated February 28,
2019 that you will
       complete the information in the Selling Security Holder table prior to
seeking
       effectiveness of the registration statement and note further that you
have not yet
       completed the information. Given the apparent nature and the size of the
offering relative
       to the number of non-affiliate shares outstanding, please provide us an
analysis explaining
       your basis for determining that the offering is eligible to be made
pursuant to Rule
       415(a)(1)(i) and why the offering is not an indirect primary offering.
In this regard, please
       advise as to whether the Notes and shares are assignable by the holders,
whether the
       holders are underwriters, and the prospectus delivery requirements for
the holders. In
 Bridgette Roman
CCF Holdings LLC
May 6, 2019
Page 2
         responding, please consider the guidance provided in Compliance &
Disclosure
         Interpretations, Securities Act Rules, Question 612.09. In addition,
revise the prospectus
         to provide the disclosures required by Item 201 of Regulation S-K.
        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.

       Refer to Rules 460 and 461 regarding requests for acceleration. Please
allow adequate
time for us to review any amendment prior to the requested effective date of
the registration
statement.

       You may contact Christina Harley at 202-551-3695 or David Irving at
202-551-3321 if
you have questions regarding comments on the financial statements and related
matters. Please
contact Erin Purnell at 202-551-3454 or Michael Clampitt at 202-551-3434 with
any other
questions.



FirstName LastNameBridgette Roman                              Sincerely,
Comapany NameCCF Holdings LLC
                                                               Division of
Corporation Finance
May 6, 2019 Page 2                                             Office of
Financial Services
FirstName LastName