United States securities and exchange commission logo May 9, 2023 Sterling Griffin Chief Executive Officer Harbor Custom Development, Inc. 1201 Pacific Avenue, Suite 1200 Tacoma, WA 98402 Re: Harbor Custom Development, Inc. Registration Statement on Form S-1 Filed May 1, 2023 File No. 333-271550 Dear Sterling 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 Kibum Park at 202-551-6836 with any questions. Sincerely, Division of Corporation Finance Office of Real Estate & Construction cc: Josephine Aranda, Esq.