United States securities and exchange commission logo December 30, 2020 Sterling Griffin Chief Executive Officer and President Harbor Custom Development, Inc. 11505 Burnham Dr., Suite 301 Gig Harbor, Washington 98332 Re: Harbor Custom Development, Inc. Draft Registration Statement on Form S-1 Submitted December 23, 2020 CIK No. 0001784567 Dear Mr. Griffin: This is to advise you that we do not intend to review your registration statement. We request that you publicly file your registration statement no later than 48 hours prior to the requested effective date and time. Please refer to Rules 460 and 461 regarding requests for acceleration. 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. Please contact Ronald (Ron) E. Alper at 202-551-3329 with any questions. Sincerely, Division of Corporation Finance Office of Real Estate & Construction cc: Lynne Bolduc