October 3, 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 3 to Offering Statement on Form 1-A
           Filed August 20, 2019
           File No. 24-10987

Dear Mr. Ellenburg:

       We have reviewed your amended offering statement and have these
additional comments. In some of our comments, we may ask you to provide us
information so
that 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 that our comments apply to your
facts and
circumstances or do not believe that 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.

1.     According to the Results of Operations section, monthly operating
expenses
       approximating $80,000 per month, accrued monthly operating expenses, and
interest on
       accrued monthly operating expenses, will be paid to ERC Parent starting
at the
       commencement of this offering. If these expenses will be paid from the
proceeds of this
       offering, please clarify in the Use of Proceeds section.
2.     We note your response to Comments one and two in our July 30, 2019
letter. We remain
       concerned that ERC Parent should be listed as a co-issuer and that the
Operating
       Subsidiaries' offerings should be aggregated. Please tell us how the
Operating
       Subsidiaries' offerings are distinct investment opportunities. In your
response, address the
       following:

           tell us what costs are included in the "indirect capitalized costs"
that will be
           "reimbursed proportionally to the entity to which they relate." See
page 29 of the
           Offering Circular and Section 5(ii) of the Management Services
Agreement. We also
 Gerald Ellenburg
ERC Homebuilders 1, Inc.
October 3, 2019
Page 2
              note your statement on page 37 of the Offering Circular that "ERC
Homebuilders 1
              and ERC Homebuilders 2 will reimburse ERC Parent for the services
of the officers
              in accordance with the Management Services Agreement;" however,
the
              Management Services Agreement does not explicitly address the
officers'
              compensation.

              that ERC Parent will license to the Operating Subsidiaries the
intellectual property
              and business concepts and design necessary to develop single
family home
              communities for lease or sale on the locations that the Operating
Subsidiaries acquire.

              that the Operating Subsidiaries rely on the same management team
from ERC Parent
              and the boards of the Operating Subsidiaries are composed of the
directors and
              officers of ERC Parent.

              that, because of your lack of revenue, proceeds from the offering
will be paid directly
              to ERC Parent, including for monthly operating expenses
approximating $80,000 per
              month, accrued monthly operating expenses, interest on accrued
monthly operating
              expenses, and a $80,000 monthly management fee.

3.       We note your risk factor disclosure on page 12 that "[t]he company
intends to secure
         mortgage financing to fund up to 70% of its first Florida developments
and plans to use
         debt financing to develop and construct subsequent Build-For-Rent
properties." Please
         advise how the Operating Subsidiaries intend to obtain mortgage
financing given their
         limited capital and assets, including whether ERC Parent will be
responsible for
         obtaining such financing and whether ERC Parent will serve as a
guarantor.
        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 Edward Kelly at (202) 551-3728 or Sherry Haywood at
(202) 551-3345
with any other questions.



FirstName LastNameGerald Ellenburg                             Sincerely,
Comapany NameERC Homebuilders 1, Inc.
                                                               Division of
Corporation Finance
October 3, 2019 Page 2                                         Office of Real
Estate & Construction
FirstName LastName