United States securities and exchange commission logo June 9, 2020 James S. Byrd, Jr. Chief Executive Officer Legion Capital Corporation 301 E. Pine Street Suite 850 Orlando, FL 32801 Re: Legion Capital Corporation Post-Qualification Amendment No. 3 to Offering Statement on Form 1-A Filed May 29, 2020 File No. 024-11123 Dear Mr. Byrd: We have reviewed your amendment and do not have any comments. 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. You may contact J. Nolan McWilliams, Attorney-Advisor, at (202) 551-3217 or Justin Dobbie, Legal Branch Chief, at (202) 551-3469 with any questions. Sincerely, Division of Corporation Finance Office of Finance