July 30, 2019

Gerald Ellenburg
Chairman and Chief Executive Officer
ERC Homebuilders 1, Inc.
2738 Falkenburg Road South
Riverview, FL 33578

       Re: ERC Homebuilders 1, Inc.
           Amendment No. 2 to Offering Statement on Form 1-A
           Filed July 15, 2019
           File No. 24-10987

Dear Mr. Ellenburg:

      We have reviewed your amended offering 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 offering 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 offering statement and the
information you
provide in response to these comments, we may have additional comments. Unless
we note
otherwise, our references to prior comments are to comments in our May 9, 2019
letter.

Amendment 2 to Offering Statement on Form 1-A filed July 15, 2019

General, page i

1.    It appears to us that ERC Parent may be a co-issuer of the securities. As
such, please
      revise to include ERC Parent as a co-issuer of the securities offered and
include all related
      disclosure for ERC Parent or advise.
2.    In this regard, it appears that the aggregate amount of the offerings of
ERC Parent and
      ERC Homebuilders 1, Inc. and ERC Homebuilders 2, Inc. would exceed the
$50 million
      limitation for Tier 2 offerings pursuant to Regulation A. Please advise.
Exhibit 12, page 1
 Gerald Ellenburg
ERC Homebuilders 1, Inc.
July 30, 2019
Page 2
3.       The disclaimer that "No opinion is being rendered hereby with respect
to the truth and
         accuracy, or completeness of the offering statement or any portion
thereof" is
         inappropriate because the legal opinion is part of the offering
statement. Please file a
         revised legal opinion.
4.       Please have counsel revise the legal opinion to opine as to the laws
of Delaware, your
         state of incorporation.
5.       Please have counsel revise the legal opinion to consent to the
prospectus discussion of the
         legal opinion and being named in the registration statement. See Staff
Legal Bulletin No.
         19 Section IV.
Offering Circular's Cover Page, page 1

6.       You disclose that "the minimum investment is $504 (84 shares)" in the
paragraph after
         footnote (2). Please revise your disclosure to reflect that the
minimum investment is $500
         (83.33 shares).
        You may contact Ameen Hamady at (202) 551-3891 or Terence O'Brien at
(202) 551-
3355 if you have questions regarding comments on the financial statements and
related
matters. Please contact Ed Kelly at (202) 551-3728 or Sherry Haywood at (202)
551-3345 with
any other questions.



                                                               Sincerely,
FirstName LastNameGerald Ellenburg
                                                               Division of
Corporation Finance
Comapany NameERC Homebuilders 1, Inc.
                                                               Office of
Manufacturing and
July 30, 2019 Page 2                                           Construction
FirstName LastName