United States securities and exchange commission logo September 16, 2021 Sterling Griffin Chief Executive Officer Harbor Custom Development, Inc. 11505 Burnham Dr., Suite 301 Gig Harbor, Washington 98332 Re: Harbor Custom Development, Inc. Registration Statement on Form S-1 Filed September 10, 2021 File No. 333-259465 Dear Mr. Griffin: This is to advise you that we have not reviewed and will not review your registration statement. 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 Shih-Kuei Chen at 202-551-7664 with any questions. Sincerely, Division of Corporation Finance Office of Real Estate & Construction cc: Lynne Bolduc