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                             October 20, 2022

       Robert Tetsch
       Chief Executive Officer
       HARRISON VICKERS & WATERMAN INC
       5781 Schaefer Avenue
       Chino, CA 91710

                                                        Re: HARRISON VICKERS &
WATERMAN INC
                                                            Offering Statement
on Form 1-A
                                                            Filed on October
14, 2022
                                                            File No. 024-12031

       Dear Robert Tetsch:

                                                        This is to advise you
that we do not intend to review your offering statement.

               We will consider qualifying your offering statement at your
request. In connection with
       your request, please confirm in writing that at least one state has
advised you that it is prepared
       to qualify or register your offering. 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.

              Please contact Janice Adeloye at 202-551-3034 or Cara Wirth at
202-551-7127 with any
       questions.




                             Sincerely,


                             Division of Corporation Finance

                             Office of Trade & Services