January 21, 2020

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. 4 to Offering Statement on Form 1-A
              Filed January 3, 2020
              File No. 024-11016

Dear Mr. Loeffler:

       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 December 20,
2019 letter.

Security Ownership of Management and Certain Stockholders, page 65

1.     We partially reissue comment 6 of our letter. We continue to note that
footnote one
       states the table does not reflect the conversion of convertible debt
securities into class a
       common stock. We also note the reference to convertible debt in footnote
10 to the
       financial statements on page F-29. If the convertible debt may be
converted within 60
       days, please revise the table to include such conversions, as required
by Item 403(a) of
       Regulation S-K and Exchange Act Rule 13d-3(d)(1). Please also describe
the terms of
       conversion for the convertible debt.
 John C. Loeffler, II
CaliberCos Inc.
January 21, 2020
Page 2

Repurchase and Redemption of Shares, page 72

2.     We note your response to comment 7 of our letter. Your disclosure
indicates that you
       will redeem shares at the "per share price of the Series B preferred
shares offered."
       However, in this section you state that you agreed to repurchase Donnie
Schrader's
       shares at $2.70 per share. Please clarify if you will repurchase Mr.
Schrader's shares at
       $2.70 per share or $4 per share. If you will repurchase at $4, please
clarify if you have
       amended the agreement with him to account for the change in price.

Plan of Distribution, page 78

3.     We note your response to comment 8 of our letter. Please clarify whether
all purchases
       will be made through the online platform or whether investors may
purchase by other
       means. If investors may purchase other than through the platform,
clarify whether the
       2% transaction fee will still apply. If not, please revise the
disclosure throughout the
       offering circular to make clear that investors will be paying a 2%
premium if they
       purchase through the online platform.

Exhibit 12

4.     Please have counsel revise the legal opinion to include the common
shares to be qualified
       in this offering.


        We will consider qualifying your offering statement at your request. If
a participant in
your offering is required to clear its compensation arrangements with FINRA,
please have
FINRA advise us that it has no objections to the compensation arrangements
prior to
qualification.

        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. We also remind you that, following qualification of your
Form 1-A, Rule 257
of Regulation A requires you to file periodic and current reports, including a
Form 1-K which
will be due within 120 calendar days after the end of the fiscal year covered
by the report.
 John C. Loeffler, II
CaliberCos Inc.
January 21, 2020
Page 3

       You may contact Kristi Marrone at (202)551-3429 or Kevin Woody 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)551-3357 with any other
questions.


                                                          Sincerely,

                                                          /s/ Pamela Howell
                                                          for

                                                          Joel Parker
                                                          Office Chief
                                                          Office of Real Estate
and
                                                          Commodities

cc: Thomas Poletti, Esq. (via e-mail)