April 10, 2020

Gary J. Simon, Esq.
Hughes Hubbard & Reed, LLP
One Battery Park Plaza
New York, New York 10004

       Re:     Broadway Financial Corporation
               Soliciting Material filed pursuant to Exchange Act Rule 14a-12
filed by
                   Commerce Home Mortgage, LLC, Steven A. Sugarman, Carlos
Salas,
                   Antonio Villaraigosa et al.
               Filed April 9, 2020
               File No. 1-39043

Dear Mr. Simon:

       We have reviewed the filing above and have the following comment. In
some of our
comment, we may ask you to provide us with information so we may better
understand the
disclosure.

       Please respond to this letter by amending the filing or by providing the
requested
information. If you do not believe our comment apply to the participants' facts
and
circumstances or do not believe an amendment is appropriate, please tell us why
in your
response.

        After reviewing any amendment to the filings and the information you
provide in
response to this comment, we may have additional comments. All defined terms
used in this
letter have the same meaning as in the soliciting material filed pursuant to
Exchange Act Rule
14a-12 unless otherwise indicated.

1.     We note that the soliciting material filed pursuant to Exchange Act Rule
14a-12 indicates
       that Commerce "currently intends to undertake an exempt solicitation
whereby it plans to
       contact up to ten shareholders to seek their support for its proposals
and its director
       nominee for the 2020 annual meeting of stockholders of" Broadway. Given
(1) the
       definition of "solicitation" in Exchange Act Rule 14a-1(l)(1)(iii), (2)
that the soliciting
       material filed pursuant to Rule 14a-12 was not required to be filed, (3)
that the
       solicitation was filed on www.sec.gov, making such communication
available to the
       general public, including all shareholders of Broadway, and (4) the
substance of the
       communication, please advise why Commerce believes it is eligible to
rely upon Rule
       14a-2(b)(2). In responding to this comment, refer to Proxy Rules and
Schedules
       14A/14C Compliance and Disclosure Interpretation Q&A 122.03 (last
updated July 31,
       2018) and its discussion of how a filing itself can constitute a
widespread solicitation that
       may preclude reliance upon Rule 14a-2(b)(2). In contrast to the guidance
provided
 Gary J. Simon, Esq.
Hughes Hubbard & Reed, LLP
April 10, 2020
Page 2

       therein, address the fact that in this particular case, Commerce had no
obligation to file
       the material pursuant to Exchange Act Rule 14a-12.

2.     Please advise us in your response letter what other solicitations have
been made to
       shareholders of Broadway, whether or not made in reliance on Rule
14a-2(b)(2).

                                              *    *   *

        We remind you that the filing persons are responsible for the accuracy
and adequacy of
their disclosures, notwithstanding any review, comments, action or absence of
action by the staff.

       Please contact me at (202) 551-3444 with any questions.

                                                             Sincerely,

                                                             /s/ Perry J.
Hindin

                                                             Perry J. Hindin
                                                             Special Counsel
                                                             Office of Mergers
and Acquisitions