September 10, 2019

Byron C. (Chris) Wiley
President and Manager
Wiley Area Development LLC
572 Breckenridge Way
Beavercreek, OH 45430

       Re: Wiley Area Development LLC
           Amendment No. 2 to
           Offering Statement on Form 1-A
           Filed August 27, 2019
           File No. 024-11010

Dear Mr. Wiley:

      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 August 12,
2019 letter.

Amendment 2 to Form 1-A

Financial Statements
Notes to Financial Statements
7. Subsequent events, page 123

1.    Refer to your response to comment 7. We continue to have concerns
regarding your
      presentation of the increase in Class A and Class B Units subsequent to
year-end. You
      indicate the increase in the number of Class A Units and Class B Unit was
an
      administrative change which increased each class of units by a multiple
of 50 and disclose
      in the subsequent events footnote the change was for purposes of enabling
the company to
      sell Class B Units at a lower per unit price. In this regard, the form of
the transaction
 Byron C. (Chris) Wiley
Wiley Area Development LLC
September 10, 2019
Page 2
         appears meet the definition of a stock split pursuant to ASC
505-20-25-4. Please be
         advised that since the transaction took place subsequent to year-end,
SAB Topic 4C
         requires retroactive effect in balance sheet if the change in capital
structure (e.g. stock
         split) occurs after the latest balance sheet date. Accordingly, please
revise your filing to
         retroactively reflect the 50-for-1 stock split, including appropriate
disclosure concerning
         the details of the split in the financial statements and elsewhere in
the document as
         appropriate.
       You may contact Heather Clark at 202-551-3624 or Jean Yu at 202-551-3305
if you have
questions regarding comments on the financial statements and related matters.
Please contact
John Stickel at 202-551-3324 or J. Nolan McWilliams at 202-551-3217 with any
other questions.



FirstName LastNameByron C. (Chris) Wiley                        Sincerely,
Comapany NameWiley Area Development LLC
                                                                Division of
Corporation Finance
September 10, 2019 Page 2                                       Office of
Transportation and Leisure
FirstName LastName